Category: Transfer pricing

The transfer pricing regulations in force since January 2019 have introduced numerous changes in this respect, such as for example:

• new documentation thresholds,
• the obligation for related entities to submit information on transfer prices TPR-C (legal persons) or TPR-P (natural persons) to the Head of the National Fiscal Administration,
• an obligation to make a statement confirming that the transfer pricing documentation has been prepared and that the transactions are carried out on arm’s length principle.

In connection with the SARS-CoV-2 pandemic, many companies are confronted with problems such as reduced income, production downtime, delays in the supply of materials and raw materials, insolvency of contractors, etc.

In practice, this may lead to situations where the supply chain in transactions with related parties has to be reorganised due to the temporary closure of the plant, lack of staff, the need for longer storage of goods due to lack of transport capacity, etc.

Advanced pricing agreements are a type of agreement with the head of the National Revenue Administration in which it was agreed that the amount and method of calculating the price applied in transactions between the companies of the group would correspond to the market price. The provisions governing the receipt of the agreement are amended, which means the following: