Transfer pricing obligations

Transfer pricing documentation:

– Mandatory for companies with a total annual turnover over than 2.9 million Eur.

Disclosure (Annex FR0528 to corporate income tax return):

– Mandatory, if the contract/group of contracts or the loan exceed 90 thousand Eur.

Market price:

– Mandatory to make all transactions at market prices (arm’s length principle);

– Tax administrator has means allowing to adjust transaction prices.