Tax
Forvis Mazars is a global integrated firm with presence in major economies of the world, so we understand the complexities of tax in today’s global economic climate.
If taxpayers prepared local transfer pricing documentation in accordance with the amended provisions in force from the beginning of 2019 in the above mentioned statement, apart from confirmation that the transfer pricing documentation has been prepared, in addition they must state that prices in transactions covered by local documentation are set in accordance with the arm’s lenght principle.
According to the new regulations, the statement should be signed by the head of the unit within the meaning of the Accounting Act. It is not possible to submit a statement by a proxy.
Regardless of the choice made with regard to the applied regulations regarding transfer pricing documentation, taxpayers for 2018 are obliged to submit a CIT-TP form (if their revenues or costs within the meaning of the Accounting Act in 2018 exceeded the equivalent of EUR 10 million).
Information on transfer prices on the new TP-R form will be submitted only in relation to transactions carried out in 2019 (detailed information in this respect will be sent to you after the holidays).
In the event of taxpayers failing to comply with the reporting obligations regarding transfer pricing, penal sanctions may be imposed on Management Board Members.
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