On 29 January 2018, the tax administration issued the new guidance No.A129/200/2017 on transfer pricing documentation, which replaces the previous guidance of 2007.
The documentation requirement is divided into a master file and a local file. The documentation must be submitted by 60 days upon request from the tax administration.
The documentation of the master file must contain organizational structure data based on § 14b (1) (1) VML. It must contain information about the legal ownership structure of the group of companies. The local file must contain a description of the organizational and management structure, including the internal reporting requirements for the management. Business information, including information about business strategy and corporate restructuring, intangible transfers information also contained in the local file. The formation of transactions with affiliates and transactions between a company and its permanent establishment (§ 14b (2) (4) VML) must be included in the local file.
