Decree containing detailed transfer pricing rules issued
The decree containing the detailed rules for transfer pricing has been issued without substantial changes*, the draft version of which and the scope of the future transfer pricing reporting obligation were previously presented in our blog. Starting from 2023, taxpayers will be subject to a new reporting obligation regarding their transfer pricing reports, as information on related-party transactions will need to be included as a new element in corporate income tax returns as well. In addition to this new administrative obligation, the threshold for preparing reports has also changed. The most important changes and tasks for companies following the entry into force of the final transfer pricing decree are presented below.
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