Time flies and the deadline to analyze, fill in and submit the TPR form rapidly approaches. Despite the existence of an interactive form and extensive explanations from the Ministry of Finance, filling in this form is time consuming and should be well thought through.

The Ministry of Finance published draft explanations to the TPR form, containing 36 pages of questions and answers to the issues raised by taxpayers. Despite the published answers to the questions, a lot indicates that in practice it may still be difficult to fill in the form. The form itself may be a limitation here - both to the extent resulting from the restrictions imposed by the shape of the regulation and from the use of the interactive pdf form itself.

In the course of the public consultation, we as Crido, in cooperation with our clients, made a number of comments on the draft explanations to facilitate the completion of the form.

Our current practice resulting from cooperation with clients who have already attempted to fill in the TPR form indicates that it may be problematic and time consuming. This is particularly evident in:

  • calculating the profitability indicators for specific businesses or transactions,
  • classifying transactions into categories not predicted in the form,
  • providing additional information in Section F (explanations to transactions), where it is possible (and often necessary) to refer to the reported data in a descriptive manner,
  • proving that transfer prices are at arm’s length with an appropriate transfer pricing method,
  • maintaining consistency with the grouping of transactions for documentation purposes.

It’s worth remembering that the purpose of the TPR form is to select companies for transfer pricing audit, submitting incorrect TPR report may result in severe fiscal penalties. Therefore, TPR form should not be treated as just another reporting obligation. TPR is a "picture" of a taxpayer's transfer pricing policy and should be with filled in with the utmost detail and diligence.

In order to meet the expectations of our clients we have developed a compact tool - Easy TPR-C'rido Tool - to facilitate and speed up the process of filing in and submitting the TPR form. The tool is updated with the latest guidelines from the Ministry of Finance and contains practical tips resulting from our experience in filling in the TPR form, and will also be updated in the future, once new tips and Q&As are published by the Ministry of Finance. Easy TPR allows you to work freely on TPR form and then save it safely and have it ready to send as an xml file to the National Revenue Administration.