Transfer Pricing: documentary obligations

2023 precos de transferencia scaled

The deadline for submission of the dossier ends on July 15

The documentation process concerning the policy adopted in the field of transfer pricing is mandatory for taxable persons who have reached a total annual amount of income exceeding 10 million euros in the tax period in question.

However, taxable persons with linked transactions whose value in the period has not exceeded, per counterparty, 100 thousand euros and, in its totality, 500 thousand euros, considering the respective market value, are exempt from this obligation.

Taxable persons who do not benefit from any of these exemptions, but who qualify as SMEs and are not accompanied by the Large Taxpayers Unit (UGC), should instead have a simplified file of documentation on the policy adopted on transfer pricing.

The exemptions provided for are not applicable to transactions carried out with entities based in tax havens, nor do they prevent proof that the terms and conditions practiced in the respective linked operations respect the principle of full competition, and the Tax Authority may notify the taxpayer for the submission of documentation at any time.

It should be noted that where transfer pricing requirements are not deemed to be met, entities should make corrections in determining taxable profit by the amount corresponding to what they would have obtained if the transactions had been carried out in a normal market situation.

See all relevant information about Transfer Pricing in the publication developed by Moneris tax experts:

How can Moneris help?

If your company establishes with other related entities some type of transaction, namely sharing of costs or services, acquisitions or sales of goods and loans, it is important to rely on a specialized team to respond to this obligation.

In addition to complying with the legal requirement, a well-designed transfer pricing strategy allows you to optimize your tax situation, manage the inherent risks and also improve management control and analysis of the performance of the different business areas.

Get to know our proposal: | 210 316 400.

Scroll to Top