When must related enterprises prepare transfer pricing documentation?

Related enterprises are required to apply the arm’s length principle when determining prices for transactions between them and, depending on the value of the transactions, they are also required to prepare transfer pricing documentation.

Segmentation – the greatest challenge of the new transfer pricing rules

One of the key challenges arising from the new transfer pricing regulation is the tightening of segmentation requirements. This is especially relevant for meeting transfer pricing obligations for the 2025 tax year, as this is a transitional year during which certain areas may already be subject to the new rules, while others must continue to be handled under the previous requirements.

 

The new transfer pricing regulation brings relief for smaller businesses, while imposing even stricter requirements on larger ones.

From 2025, we are saying goodbye to the previous transfer pricing regulation and introducing a new one, which affected parties may choose to apply already for the previous year. However, from 2026 onwards, its application will be mandatory. While the new rules do include certain simplifications, they are much more characterized by stricter requirements.