On 12 August 2019, the tax authorities released the new transfer pricing (TP) rules, which will apply from 2019, in addition to the previously announced new TP rules. The tax authorities also include the following TP measures:
Abolishing the hierarchy in the selection of the transfer pricing method. From 2019, however, the chosen TP method will have to be justified as the most appropriate; and
Establishment of disputes settlement procedures under Regulation No VA-57 (Rules for the Initiation and Implementation of the Mutual Agreement Procedure) of the Head of the State Tax Inspectorate of the Ministry of Finance.