The Ministry of Finance proposes another change in transfer pricing to seal the tax system. According to the plans, the changes will enter into force. 1 January 2019.
one from the proposed amendments, the rules on market price fixing are clarified. The tax documentation of transfer prices concerns, inter alia, the assessment of whether the price applied by the parties was market-oriented (i.e. not artificially understated or overstated). The amendment proposed by the Ministry of Finance also aims to facilitate the verification of the price valuation by tax authorities.
The Resort also wants to harmonise some key concepts related to transfer pricing documentation. To this end, a definition of certain legal concepts is planned to remove interpretation doubts.
We invite you to isolate from transfer prices
Another novelty is the possibility of using documentation prepared for another entity in a given group. This is about group documentation. Obtaining adequate documentation from another entity may result in the absence of the need to produce documentation on its own.
The Ministry of Finance project also proposes to extend certain time limits for documentation obligations. Some taxpayers may find it difficult to draw up documentation on a new basis in due time. The extension of the statutory time limits aims to avoid potential difficulties.
The legislator also proposes to simplify the setting of the thresholds for the amounts on which the obligation to draw up transfer pricing tax records depends.