On 10 June 2026, the Government Legislation Centre published a new proposal to amend personal and corporate income tax legislation (UDER 107). The proposal builds on an earlier draft published on 31 March 2026, following calls from taxpayers and practitioners during the public consultation process to scrap certain TP regulations. This time the changes amount to genuine deregulation.

What will change?

Major proposed changes include:

  • simpler rules on who is authorised to sign Form TPR,
  • reducing TPR content requirements by removing the declaration that the TP documentation is true to facts and the transfer prices are at arm’s length (TP Declaration),
  • exempting microenterprises and small enterprises from the requirement to include general ratios in their TPR filings.

TP Declaration to be abolished

Businesses have been required to make a declaration that their TP file has been prepared in accordance with the facts while their transfer prices are as between unrelated parties. As of 2019, this has been a stand-alone document to be signed by the management (as defined in the Accounting Act), and signature by an agent has been prohibited (with certain exceptions listed in the law).

Since 2022, TP Declaration has been part of form TPR, meaning the entire form could only be signed by a strictly specified range of people (e.g. management or a designated member of a collegiate governing body), with very limited options for authorising others to sign under a power of attorney.

The new law would repeal the legacy regulations that put TP Declaration in form TPR, including Article 23zf(2)(7) and 23zf(2b) of the PIT Act and Article 11t(2)(7) and 11t(2b) of the CIT Act.

At the same time, the drafters backed from their original plan to shift TP Declaration to the local file or to amend the criminal tax code to penalize a failure to make such a declaration in the local file.

Simpler rules on who may sign Form TPR

Previously, Form TPR could be signed only by a limited range of people (e.g. the management as defined in the Accounting Act, or a designated member of a collegiate governing body), with the involvement of agents for the purpose being restricted except in the case of advocates, attorneys-at-law, tax advisors, and independent auditors.

The new law would:

  • repeal article 23zf(5) and 23zf(5a) of the PIT Act and Article 11t(5) and 11t(5a) of the CIT Act, which defined a close-ended list of who is authorised to sign form TPR and imposed liability for failure to designate a member of a collegiate governing body for the purpose of singing such form;
  • lay down a rule that Form TPR is to be signed in accordance with Article 3b of the Tax Code, meaning it can be signed by an agent authorised to sign electronic instruments under a UPL-1 authorisation form.

Also, the draft elaborates on the applicability of Tax Code’s adjustment/amendment regulations to Form TPR (added Article 23zf(5c) in the PIT Act and Article 11t(5c) in the CIT Act), making it clear that Form TPR may be adjusted/amended. This is merely a clarification as adjustments/amendments to Form TPR have been authorised under the general rules of the Tax Code, as confirmed in annual explanatory guidance published by the Finance Ministry.

When will the new law enter into force?

In accordance with transitional provisions:

  • the previous law (including the TP Declaration requirement and the legacy TPR signature regulations) will continue to apply to TPR filings made for any tax years that began before 1 January 2026;
  • the law that amends the TPR signature rules, repeals TP Declaration and exempts microenterprises and small enterprises from having to report general ratios will apply to TPR filings made for any tax year that begins or began after 31 December 2025.

What is the impact on taxpayers?

  • Fewer formalities for the management/executives – the required personal signature of management/designated director will be replaced by Tax Code’s general signature rules allowing, among other things, for signature by agents acting under UPL-1 authorisation.
  • No TP Declaration – whether as a separate document or as part of Form TPR or local file.
  • Now new criminal penalties in relation to TP Declaration – drafters backed from plans to impose additional liability for not ensuring that TP Declaration is included in the local file.

The new law simplifies transfer pricing reporting and scraps earlier plans that increased criminal tax risks in relation to TP Declaration while retaining the ability of tax authorities to verify the arm’s length level of the prices and the quality of the file. Importantly, the criminal tax liability for a failure to timely prepare a local file or preparing one that is not true to facts remains and nothing changes in this department.

If this issue pertains to your business and you are interested in our assistance, please contact us.

This blog post is provided for general information purposes to keep you up-to-date with changes in tax law, tax rulings by authorities, case law of courts and interesting commentaries. Doradztwo Podatkowe WTS&SAJA shall not be held legally liable for any acts or omissions resulting from reliance on such information.