Preparing TPR-C is easy with our Easy TPR-C’rido Tool

2019 brought another change to the transfer pricing regulations that impose even more detailed transfer pricing reporting obligations on taxpayers, as compared to previous years. One of the biggest challenges in 2020 is to report the transfer pricing information to the Head of the National Revenue Administration via the TPR-C form (TPR-P for personal income tax) for FY2019. The obligation to submit the TPR form was imposed by the CIT Act followed by the executive Minister of Finance Regulation on transfer pricing information announced in December 2018.

An explanatory memorandum to the Regulation indicates that the transfer pricing information has a “simplified and transparent form” and that submitting it in electronic form based on the XML schema “will allow for a significant reduction in the time needed to fill in the information, as well as increase its transparency and significantly simplify the process of filling in the information itself“.

The Regulation itself is short – it is in fact only 2 pages long, but the explanatory notes issued with it have 18 pages. However, both documents do not give sufficient guidance to taxpayers on how to submit the information. Hence in May 2020 the Ministry of Finance published a preliminary version of the Questions and Answers, which are supposed to dispel the taxpayers’ doubts. The Q&A document is already 36 pages long and has been subject to public consultation, so the next version may be even more extensive.

Despite these few documents explaining the TPR form, it still arouses a lot of controversy, and once the taxpayers start filling it in, further questions and doubts arise. And the deadline for reporting, although postponed, is inevitably approaching.

TPR reporting - The transfer pricing information (TPR) is used to analyse the risk of underestimating taxable income with respect to transfer pricing

What information is reported in TPR?

  • Classifying transactions into correct categories
  • Information on the transfer pricing methods and prices applied in I/C transactions
  • Detailed inthe methods of verifying transfer prices as arm’s length, i.e. whenther internal or external comparable data was used, what is the arm’s length range,
  • Information on the TP adjustments made
  • Information on safe harbours applies for service or financial transactions
  • Any additional explanations, if needed

Public consultation on TPR form and the draft Q&A prepared by Ministry of Finance was open till 22 May 2020.

Easy TPR-C’rido Tool

We have designed a unique tool to facilitate preparing the TPR-C form, full of tips and clues from our experience, intuitive to fill in, regularly updated to the latest official standpoint of the Ministry of Finance, easy to convert to .xml file and sent to National Revenue Administration.


Why use our Easy TPR-C'rido Tool?

  • It is a functional worksheet that allows you to fulfil the obligation to report transfer pricing information in an easier, quicker and more automated way
  • It is an intuitive tool to fill in, contains both a reference to the current position of the Ministry of Finance on what information should be included and how it should be presented and our practical tips
  • The tool prepared in accordance with the current TPR-C form and scheme published by the Ministry of Finance, it is also regularly updated by us if the official format changes
  • Using the tool reduces risk of data loss or inability to correct data in the form
  • The tool improves and speeds up the completion of the form by, among other things, copying transactional data
  • It enables secure recording and storage of the completed form in accordance with internal archiving procedures, also for the purposes of possible tax audits
  • The tool allows you to easily convert a completed form into xml format and send it to the Head of the National Revenue Administration

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