Anticipated extension of deadlines for meeting transfer pricing obligations for 2021
April 2022
The government's draft act on amendments to certain laws, dated April 4, 2022, including amendments to the
COVID Act, providing for facilitations for taxpayers with respect to transfer pricing, has been published on the government's website.
The most important change from the taxpayers' point of view is the extension of the deadlines for filing the TPR form
together with the statement on fulfilling the obligations related to local transfer pricing documentation.
In addition, the draft introduces the possibility of taking advantage of the exemption for domestic transactions
concluded between foreign establishments which have incurred a tax loss (on the condition of total revenues
at least 50% lower in a given tax year than the total revenues obtained in the corresponding period immediately
preceding this year).
It is also worth noting that other reliefs for transfer pricing taxpayers have been upheld, e.g. it is not required to have
a transfer pricing adjustment statement, extension of the deadline for the Master File, or extension of the catalog of
persons authorized to sign the TP statement.