Can transfer pricing information be signed by an attorney?

Yes. Signing the TPR information by an attorney is allowed on principles similar to signing other information or tax returns. However, other rules apply to signing the statement on preparation of local transfer pricing documentation referred to in Article 11m section...

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How should I submit the TPR information?

The TPR form should be submitted to the Head of the Cashier by e-mail. The deadline for submitting the form for 2019 is the end of December 2020. (extended by 3 months due to COVID-19). The electronic pdf form was prepared by the Ministry of Finance and is available...

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What is the recharacterisation of the transaction?

Under the amended regulations, the tax authority will be able to perform the so-called recharacterisation of a transaction with a related party and assess the tax consequences resulting from this newly classified transaction. It will also be able to consider that no...

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