Step 5 – Transfer pricing statement and filing of the TPR form

6 steps to TP without (active) repentance

In most cases this will be the final step/completion of the TP reporting process. All that remains to be done is submit the TPR form to the Head of the National Tax Administration and timely file the statement of preparation of the Local File and application of arm’s length prices (transfer pricing statement) with the competent tax office.

In the transfer pricing statement, the Management Board states that:

  • transfer pricing documentation has been prepared;
  • transfer prices in controlled transactions covered by the Local File are at arm’s length.

Please note that failure to submit the statement or making a false statement can potentially even incur criminal liability. However, the need to file the statement can be viewed from another angle, namely as an additional motivation for the Management Board to more thoroughly examine the issue of transfer pricing in the company.

Meanwhile, a completed TPR form can help you assess the likelihood of an audit. Experience from before the introduction of the TPR form shows that audits focused on entities with losses or low profits and those involved in restructuring processes. And the TPR may show an unfavourable financial standing of the company reflected in negative values of its financial indicators, or defaulted loans.

How we can assist

Our support includes:

  • an audit of relationships to verify that your analysis has covered all relevant transactions;
  • review of the list of transactions to be documented;
  • preparing and filing the TPR form and transfer pricing statement on your behalf.


Related services:

Tax Practice