Transfer pricing obligations
Transfer pricing documentation:
– Mandatory for companies with a total annual turnover over than 3 million Eur.
Disclosure (Annex FR0528 to corporate income tax return):
– Mandatory, if the contract/group of contracts or the loan exceed 90 thousand Eur.
– Mandatory to make all transactions at market prices (arm’s length principle);
– Tax administrator has means allowing to adjust transaction prices.