New types of Transfer Pricing reporting

New types of Transfer Pricing reporting have been adopted recently:

• Country-by-Country Report;
• Master File.

Both documents are components of three-level TP reporting and should be submitted for the first time in 2023. Therefore, currently there is no practice and explanations regarding the specifics of compiling and submitting these reports.

Mazars Tax alert answers the following questions about New types of Transfer Pricing reporting:

• When where is an obligation to file this report?
• What are the filing deadlines?
• What is reporting period?
• What is the first year to file the report?
• What is reporting format?
• What should it contain?
• How will tax authorities use the reports?
• What is the liability for failure to submit?

Note that tax authorities may request the Master File starting from January 1, 2023.