Significant tightening in transfer pricing regulations in the 2023 state budget proposal

The government has submitted Proposal T/360 on the foundation of the 2023 state budget, which affects several types of taxes.

Transfer pricing regulation is highly emphasized in the proposal package, defining significant tightening in the rules, a new reporting obligation, as well as significantly higher penalties and fees of proceedings. The new rules of transfer pricing adjustments may result in a major additional burden for several taxpayers in terms of the extra taxes to be paid.

To read the whole newsletter: 


Tax Newsletter 2022/11.