Related parties preparing local transfer pricing documentation or carrying out controlled transactions that are exempt from such documentation (e.g., domestic transactions or safe-harbour arrangements) are required to file TPR information by the end of the eleventh month following the end of the tax year.
Where the tax year corresponds to the calendar year, the filing deadline for TPR covering 2024 is 1 December 2025.
TPR information must include, i.a.:
Filing is conducted exclusively electronically. The signature may only be provided by the head of the organisation or by an authorized professional representative (tax adviser, legal counsel, attorney, or certified auditor). Failure to fulfil this obligation may expose members of management to criminal fiscal liability.
TPR is one of the tax administration’s key tools for assessing the risk of income understatement — errors, incorrect data presentation, or delays can increase the likelihood of a tax audit.
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