The end-of-May deadline for preparing the transfer pricing documentation and setting the tax base adjustments

Taxpayers with a calendar business year have to file their 2021 corporate tax, local business tax and innovation contribution returns until May 31, 2022. The transfer pricing documentation should also be prepared by the date of filing the corporate tax return, on the basis of which any necessary transfer pricing adjustments may also be determined.

The difference between the arm’s length prices and the applied transfer prices may be settled between related parties by adjusting the original value of the transaction by means of an accounting document/invoice or by adjusting the tax bases. If the time available for notifying the respective amounts to be validated against each other expires due to specific intra-group deadlines (reporting, closing), the tax base adjustment remains the only option. However, this solution carries a higher risk of double taxation. In our newsletter we summarize the most important information related to the above.

To read the whole newsletter below.