The TP-R form and transfer pricing documentation relate strictly to a specific financial (tax) year. This means that the data presented in these documents – such as transaction values or profitability indicators – should refer exclusively to that reporting period. In practice, however, businesses may, for various commercial reasons, present averaged data, e.g. from a…
In recent years, public companies have been subject to new obligations relating to transactions entered into with related parties. These obligations arise under Chapter 4b of the Act on Public Offering[1] and apply to material transactions. According to the Act on Public Offering, a material transaction is one whose value exceeds 5% of the company’s…
A well-designed and up-to-date transfer pricing model is crucial for ensuring coherent tax compliance and mitigating fiscal risks. However, the dynamic nature of market conditions and even the most carefully developed transfer pricing frameworks can require periodic updates. Why is maintaining an up-to-date transfer pricing model important? The primary purpose of transfer pricing model is…
As the financial year-end approaches—bringing tax closures and financial audits—it’s the last chance to thoroughly review settlements, pricing, and contractual terms and make any necessary adjustments. Taxpayers often ask: What are transfer pricing (TP) adjustments? Why are TP adjustments necessary? If you have any doubts about these topics, we invite you to read our latest…
What are financial transactions in the context of transfer pricing? Financial transactions encompass a wide range of intercompany activities, including loans, credit facilities, financial guarantees, bond issues, and other financial instruments. These are among the most common categories of related party transactions. To minimize the risk of income adjustments by tax authorities, the terms of…
For years, financial, service, and distribution or production transactions have consistently been the most commonly reported in the TPR form. This is largely because they are easy to identify as subject to transfer pricing regulations. However, in a complex and rapidly evolving business environment, companies often engage in transactions that do not fit neatly into…
Intangible services have long been a focus of tax authorities. It is therefore essential to understand the key risk areas associated with these service costs and to manage them proactively throughout the year—not just when preparing transfer pricing documentation. Confirmation of service performance (Benefit Test) When it comes to intangible services, taxpayers must be able…
Transactions with related parties can pose significant tax risks. Many taxpayers only identify transfer pricing (TP) issues when preparing documentation and submitting the Transfer Pricing Report (TPR), at which point their ability to implement necessary corrections is limited. A financial audit presents an excellent opportunity to proactively identify risks related to intra-group transactions. As part…
The deadline for submitting the CbC-P notification for 2024 to the Head of the National Revenue Administration (KAS) is fast approaching—31 March 2025 (for entities whose financial year aligns with the calendar year). This obligation applies to entities that are part of corporate groups required to submit a Country-by-Country Report (CbC-R). What is CbC-P reporting?…
The new Notice of the Minister of Finance on the announcement of the type of base interest rate and margin for transfer pricing (safe harbor for financial transactions) has been published! Conditions for safe harbor in financial transactions The Finance Minister has updated the conditions authorizing the use of safe harbor simplification for financial transactions.…