The deadline for preparing local transfer pricing documentation for all statutorily obligated entities, whose fiscal year coincides with the calendar year, is near - December 31st, 2022. What is more, these entities are obliged to submit the TPR declaration to the Head of KAS and submit a statement on the preparation of transfer pricing documentation, signed by the Company's representatives, to the correlating Tax Office.
Penalties and sanctions for a failure to comply with transfer pricing obligations are quite severe, and fiscal penal liability related to TPR lies within management board members.
The approaching new year is also a time to consider reviewing/annexing contracts. Transactions between related parties on non-market terms may result in additional tax sanctions imposed on the Company.
