Dear Readers,
The Ministry of Finance prepared draft amendments to the forms and rules for completing the three-tiered transfer pricing documentation to align with the updated provisions of the Transfer Pricing Law.
Local File
The draft introduces the following changes to the form and rules for completing a Local File:
- The obligation to submit a Local File is imposed on participants in transactions subject to transfer pricing control (previously it was imposed on members of a multinational enterprise group).
- The Local File is to be submitted only electronically. A taxpayer may submit a paper report just in the absence of the software or in case of technical errors in the software of the state revenue authority.
Master File
The submission deadline for a Master File is 30 calendar days (previously 12 months) from the day a member of the multinational enterprise group receives a request from the tax authorities to provide the Master File.
According to the updated provisions of Article 7-2 of the Transfer Pricing Law, the tax authorities may request to provide a Master File from a member of a multinational enterprise group no earlier than 12 months following the end of the corresponding financial year.
The draft order is open for public discussion until 7 August 2024.