On November 8, a draft regulation of the Minister of Finance to extend the deadlines for the submission of transfer pricing information was made available on the Government Legislation Center website.
In the draft, the Ministry of Finance justifies the decision to extend the deadlines for submitting transfer pricing information: “Due to the release of a new software on 30 October 2023, for submitting TPR Information using electronic communication means corresponding to the logical structure available in the Public Information Bulletin on the Ministry of Finance’s entity website, it is necessary to provide taxpayers with adequate time to familiarize with the new tool (transfer pricing information will be prepared for the first time on an interactive online form, in previous years taxpayers were provided with an interactive PDF form). The additional time will allow taxpayers to correctly fulfil the substantive and formal obligations of submitting TPR Information, thus the draft regulation implements the demands made by taxpayers.”
It is important to note that the submission of the TPR form will have a new format and for the first time and will no longer be an interactive PDF file, but via a tool available online on the Ministry of Finance’s website.
According to the draft regulation, the deadline for submitting transfer pricing information is extended for entities whose tax year begins after 31 December 2021:
In the justification for the draft regulation, the Ministry of Finance emphasizes that the regulation has no negative impact on the activities of microentrepreneurs and small and medium-sized enterprises.
Due to the need to carry out the legislative process, setting only a three-day period for submitting potential comments to the draft is not surprising. The proposed date of entry into force of the regulation is the day following the date of announcement.
If you have any questions regarding this topic or if you are in need for any additional information – please do not hesitate to contact us:
CUSTOMER RELATIONSHIPS DEPARTMENT
Head of Customer Relationships
Department / Senior Manager