Changes in Transfer pricing rules for 2021

Anti-tax haven rule

In 2021 Anti-tax haven rule was incorporated in the TP rules – for details see local file obligation on the first page.

New TP-R form

As from 2021 there are more detailed changes introduced in this form. For example, in case of a loan it is necessary to report both interest paid and accrued, interest will be reported to four (not two) decimal places and debt will have to be reported as of the last day of the year (not as an arithmetic mean at the beginning and end of the period). Greater detail is required in case of restructuring (e.g. transfer of employees is restructuring ) and changes in joint venture or transparent entities.

Safe harbour interest for loans

The new interest is maximum 2.3 for the borrower and minimum 2pp for the lender.