The extended deadline for the submission of transfer pricing documentation – Regulation of the Minister of Finance of 14 March 2018
Following major changes to the regulatory environment, the first documentation of transactions with related parties executed in 2017 can be drafted by 30 September 2018 and not, as originally assumed, by 31 March 2018. According to the clarifications provided by the Ministry of Finance, tax payers obligated to draft documentation of transactions with related parties are obliged to specify whether or not they take advantage of the extended deadline for drafting said documentation in their annual tax return. The use of the extended deadline for drafting the documentation will not necessitate filing a corrected tax return.
The Ministry further explained that the seven-day deadline for filing the tax documentation at the request of the tax authority exclusively applies to documentation which has gone over the filing deadline. Therefore, if a tax payer elects to draft the documentation any day before the end of September 2018, the tax authorities will not be in a position to request that the tax payer files the 2017 documentation before that date.