Transfer Pricing

A three-tier transfer pricing reporting structure is introduced:

1. Transfer pricing documentation. In the transfer pricing documentation, the taxpayer must provide a justification of the economic expediency (economic benefit) of transactions and existence of a business purpose – for transactions other than commodity ones (this rule is in effect from 23 May 2020);
2. Global transfer pricing documentation (master file) – tier 2;
3. Country-by-country report on a multinational group – tier 3.

Additionally, it is now required to submit a notification of participation in the group. Such notification will be submitted for the first time in 2021 for the year 2020.
 

The master file may be requested by a controlling authority if the total consolidated income of the group is at least EUR 50 million. The request for the master file may be sent for the first time for the year 2021.

The country-by-country report shall be submitted by the taxpayer if the total consolidated income of the group is at least EUR 750 million. The report will be submitted for the first time for the year 2021. The country-by-country report shall be subject to automatic exchange of tax and financial information.