Last call: Significant changes to take info account before submitting TPR

When planning to submit transfer pricing information (hereinafter: TPR) for the tax year beginning after December 31, 2021, it is important to remember that compared to the previous tax year, there has been a change in the existing form and scope of data reported in this declaration.

The Ministry of Finance has decided to abandon PDF documents in favor of an interactive form, completed through a dedicated website.

At the end of last year, the Ministry of Finance also published the fourth edition of the “TPR Transfer Pricing Information – Questions and Answers” (hereinafter: TPR Guidebook), regarding the new form templates, i.e. TPR-C(5) and TPR-P(5).

The new edition of the TPR Guidebook also answers the most frequently asked questions regarding transfer pricing information, with the aim of making it easier for taxpayers to meet their TPR reporting obligations.

Importantly, the TPR Guidebook provides answers to a number of highly relevant questions related to other changes introduced from 2022, specifically:

• the appropriate authority to which the TPR is submitted,
• calculation of the impact of the comparability adjustment on the result of the transfer pricing analysis,
• completing the TPR by entities with the status of micro and small entrepreneurs and the rules for determining this status by taxpayers,
• new fields in TPR, such as “Value of transactions per country.”
• including in the TPR a statement on the preparation of local documentation and market value of prices,
• the correct signing and submission of the TPR.

When filling out the TPR shortly before the deadline of January 31 this year, it is important to take the above issues into account, as it may take many taxpayers additional time to obtain some of the information necessary to include in the new version of the form. We recommend that you carefully read the new guidebook and, based on the information contained therein, submit the TPR form on time.

However, when preparing the TPR form, it is important to remember that the questions and answers contained in the TPR Guidebook are for informational purposes only and are neither a general interpretation of the tax law nor an explanation of the tax law (tax explanations).

In addition, due to the need to report additional information relative to the previous version of the form, as well as the possible occurrence of overloads on the Ministry of Finance website, we recommend not leaving this obligation to the “last minute”.