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Transfer pricing report (TPR) – a new ratio from 2022


by Joanna Tomczak

10 March 2023

Most taxpayers satisfied their 2021 transfer pricing obligations by the end of December 2022. However, it is good to start preparing now for documentation and reporting obligations for 2022. This is important because of the changes made to transfer pricing legislation in 2022. 


The amended legislation requires that taxpayers calculate and disclose a new ratio – the share of operating expenses for transactions with associated enterprises in the entity's total operating expenses in their transfer pricing report (TPR) filed for 2022. 

The obligation applies to entities other than banks and insurance and reinsurance companies and to micro and small enterprises. 

The requirement will not apply to entities that only make controlled transactions that do not need to be included in transfer pricing documentation (domestic transactions, transactions covered by APA, recharge invoices and safe harbour for loans and low-value-added services).

Challenges and obligations 

In practice, taxpayers may face serious difficulties in calculating the new ratio. They will be unable to compute it on the basis of their income statement, as they are not required to show their operating expenses split by associated and independent enterprises.

So they will only be able to calculate the ratio using their separate internal records. If the taxpayer has failed to keep separate records of operating expenses for transactions with associated enterprises, the calculation of the above ratio may be difficult and time-consuming, or even impossible.

The deadline for preparing the TPR form is November 2023 (for taxpayers whose tax year corresponds to the calendar year). However, it makes sense to review your internal systems and records in advance to know if you can extract the necessary figures to calculate the ratio. In some cases, extracting the relevant data can be a lot of work. 

For more on TP legislative changes and the merger of the TPR form with the statement, please visit roedl.en »

At Rödl & Partner, we offer comprehensive support in transfer pricing obligations. Please contact us for further information or support in preparing your TPR.


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Joanna Tomczak

Tax adviser (Poland)

Senior Associate

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