In view of the approaching deadlines for the fulfilment of documentation and information obligations in transfer pricing, we would like to remind you that with regard to the fulfilment of transfer pricing obligations for 2022, there is a fundamental change in the deadlines in relation to previous years (previously extended through the so-called Covidien provisions until 30 or 31 December of a given year):
- preparation in electronic form of local transfer pricing documentation – by the end of the 10th month after the end of the tax year, i.e., in principle – by 31 October 2023
- submission of transfer pricing information (TPR) – by the end of the 11th month after the end of the tax year, i.e., in principle – by 30 November 2023
- attaching the group transfer pricing documentation to the local transfer pricing documentation – by the end of the twelfth month after the end of the tax year, i.e., in principle – by 31 December 2023.
We would also like to draw your attention to the fact that, according to the new regulations, the transfer pricing information (TPR) for 2022 is, as a rule, signed by the competent representative of the related entity, determined in accordance with the content of Article 11t(5) of the CIT Act or Article 23zf(5) of the PIT Act – as a rule, this can only be one natural person (the system does not allow the so-called “multi-signature”). At the same time, according to the new rules, it is not permissible for this information to be signed by a proxy, as was the possibility until now, except for professional attorneys of law – which may involve additional formal obligations on the part of taxpayers.
Source: article prepared by our cooperation partner TaxAGroup
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