Extending deadlines for compliance with transfer pricing obligations

27 February 2018

The Ministry of Finance has taken measures to make the deadlines for meeting transfer pricing (TP) documentation obligations more realistic and to simplify regulations in this scope.

Extension of transfer pricing documentation filing deadline

On 16 February 2018 the Ministry of Finance announced that it was working on extending the deadlines for filing TP documentation. This refers in particular to the following obligations of taxpayers:

• preparing the transfer pricing documentation (Local File and Master File);
• submitting to a tax office a statement that the TP documentation is ready;
• filing a CIT/TP summary report together with the tax return for the fiscal year.

Affected period

The Ministry has taken measures to simplify the tax system and account for a significant interest of the taxpayers. The deadlines are planned to be extended to the last day of the ninth month after the end of the fiscal year, and not to be the same as the deadline for filing a tax return, like it is now. The amended regulations are expected to apply to the obligations that arise in 2018 (i.e. to the transfer pricing documentation, the statement and the summary report for 2017) and in 2019 (i.e. to the transfer pricing documentation, the statement and the summary report for 2018).

With the extension of the deadline for the preparation of transfer pricing documentation by six months taxpayers will not have to act under time pressure, which will surely let them meet their obligations more effectively.

Reduction of documentation obligations

Furthermore, the Ministry of Finance informed the public that at the same time it was working on an amendment that would significantly reduce and simplify taxpayers' documentation obligations. Since the changes will be favourable to taxpayers, the new regulations are planned to be implemented retroactively with effect from 1 January 2018.

We hope that the changes will minimise the amount of required data, thereby reducing the workload and the related expenses.