The expanding transfer price requirements will be followed by an increase in fines this year

“The introduction of data provision was undoubtedly the most far-reaching change in the field of transfer prices in recent times. This new obligation is not only another administrative burden, but in the case of many corporate groups, it has resulted in a rethinking of previous transfer pricing practices. In addition, the formal inclusion of data provision in the tax return can also pose a serious challenge in the timing of what needs to be done, since the tax return deadline should be taken seriously.”

– emphasizes Péter Gémesi, director of Deloitte’s tax department.

In the corporate tax return submitted after December 31, 2022, they must provide detailed information about their related transactions covered by the documentation, as well as certain transactions that are exempt from transfer pricing registration.

“Based on the experience of the previous two years, it can be concluded that the fulfillment of data provision was a challenge for all parties involved, including the tax authorities, taxpayers and consultants”

said Alex Remmers, manager of Deloitte’s tax department.

The tax authority had to answer a series of interpretation questions and cope with the huge amount of data and information received. Taxpayers had to familiarize themselves with the additional pages of the corporate tax return and fill them in with the appropriate data. If a taxpayer had a large number of transactions to be documented and therefore reported during the year, this could cause increased administrative difficulties.