Shield 4.0 - extension of transfer pricing deadlines
Under the 4.0 Anti-Crisis Shield, deadlines for transfer pricing documentation obligations have been extended. This time, the Shield 4.0 covers all entities obliged to prepare transfer pricing documentation, not only those whose tax year is different from the calendar year, as was the case with the Shield 1.0. and 2.0.
In accordance with the explanation provided by the Ministry of Finance, the extension of deadlines is to facilitate entrepreneurs' fulfilment of transfer pricing obligations and to allow them to adapt their documentation obligations to the changed deadlines for preparing financial statements.
Transfer pricing - new deadlines
Shield 4.0 introduces an extension of the deadlines for:
- the submission of transfer pricing information (TPR),
- the submission of a declaration that local transfer pricing documentation has been prepared,
- attaching group transfer pricing documentation to local documentation.
Drafting of local documentation and submission of TP-R form and a declaration of drafting local documentation under Shield 4.0:
- if the deadline expires between 31 March 2020 and 30 September 2020 - taxpayers shall have time to do so until 31 December 2020
- if the deadline expires between 1 October 2020 and 31 January 2021 - the deadline shall be extended by 3 months in relation to the statutory deadline.
Moreover, for the Master file, entrepreneurs will have time to prepare it by the end of the third month from the day following the day on which the extended deadline for submitting a declaration on drafting local transfer pricing documentation expired. This means that:
- if the deadline for submitting the above-mentioned declaration is 31 December 2020, the deadline for drafting the group documentation is 31 March 2021,
- if the deadline for submission the above mentioned declaration is extended by 3 months in relation to the statutory deadline, the taxpayer has another 3 months to prepare group documentation, starting from the day following the day on which the extended deadline for submission of a declaration on drafting local transfer pricing documentation expired.
