On 31 March 2026, the Government Legislation Centre published an on-line proposal from Finance Ministry for changes in various tax regulations designed to ease the administrative burdens on taxpayers and increase agency efficiency and performance.

Some of the changes would pertain to transfer pricing regulations, including such issues as:

  1. the range of functions authorised to sign the TPR transfer pricing filings,
  2. where specifically to put the representation that the local file is true to facts and that the prices in related party transactions are at arm’s length (“TP Representation”), and penalties for failure to make the representation.

Re. 1. According to the proposal, the authority to sign TPR filings would vest also in agents authorised to sign electronic returns (under form UPL-1), such as chief accountants. This would expand the range of authorised signatories, which is now limited to management board members and professional advisors (counsel).

Re. 2. TP Representation would no longer be part of form TPR and would instead become part and parcel of the local file for transfer pricing purposes. It could be made by a board member or professional advisor (counsel) using their qualified electronic signature.

So, unlike today, TP Representation would no longer be submitted within form TPR but would be filed only upon tax authorities’ request together with the local file.

However, this solution will also make it possible for the authorities to effectively verify if your local file has been issued on time as the date of the signature under the TP Representation will tell the time when the file was issued.

Another of the proposed amendments is to be made in the Fiscal Penal Code, which is proposed to impose criminal liability for issuing a local file that does not comply with transfer pricing regulations (such one containing no TP Representation).

The changes would apply to local files and TPR disclosures issued or filed for tax years commencing after 31 December 2025, which includes tax year 2026.

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

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