TPR forms in questions and answers – there is a third edition of the MF publication
The Ministry of Finance has published the third edition of its guide to TPR forms. It takes the form of questions and answers. It runs to 80 pages and is divided into four main parts, with the last part consisting of 14 subsections.
This publication is a practical guide to transfer pricing reporting issues, as the MF expressly stipulates that the document is neither a general interpretation nor an MF Explanatory Note. The guide is intended to facilitate the fulfilment of the transfer pricing reporting obligation. In its prepared responses, the MF takes into account comments made by taxpayers. The latest version has been expanded to include new answers to questions included in previous versions of the document and new issues have been added.
The TPR Handbook for 2021 takes into account, among other things, changes resulting from amendments to the TPR Regulations that apply to transfer pricing information filed for 2021. These changes concern the limitation of the scope of data and information indicated in the transfer pricing information for transactions that have been exempted from the obligation to attach a comparative analysis or a compliance analysis to the local transfer pricing documentation.
The TPR Handbook also contains practical examples presenting the recommended way of completing the transfer pricing information for, inter alia, financial transactions, insurance transactions or multi-year contracts.
– Although the MF document is not binding on tax authorities, it is worth emphasising that it is necessary and certainly allows taxpayers to familiarise themselves with the ministerial approach to transfer pricing reporting issues. In doubtful situations, one can refer to the guide and support oneself with the published answer, notes Cyprian Werykowski, tax adviser, director at Thedy & Partners.