For the purposes of TPR information, a given transaction should be identified as a controlled transaction of homogeneous nature within the meaning of Article 11k(2), (3), (4) and (5) of the Act – i.e. in the same way as in local transfer pricing documentation. A controlled transaction of a homogeneous nature, included in the local documentation, should be shown as one transaction in the TPR. In case of controlled transactions for which the entity has not prepared local documentation but is obliged to submit TPR information (so called “domestic transactions” under Article 11n(1) of the Act), the above rule should be applied by analogy, i.e. identification and grouping as for the purpose of determining the documentation obligation.
