Year-end transfer pricing tasks and surprises under the Christmas tree

As the end of the year is approaching, it is important for taxpayers whose business year corresponds to the calendar year to ensure compliance with the relevant statutory requirements related to the Country-by-Country Reporting (“CbCR”) and the Master File.
Furthermore, as of 2021, transfer pricing adjustments appear in the legal regulations related to the local business tax.

Towards the end of the year, it is worth reviewing whether the company has any obligations related to Country-by-Country Reporting, either in terms of reporting or only notification.

The reporting obligation applies to ultimate parent entities and designated surrogate parent entities, as well as to enterprises in the case of which the exemption from the reporting is not possible due to the fact that they do not satisfy the relevant conditions.

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