You may have noted that 1 December 2025 was the deadline to file the transfer pricing report (form TPR) by taxpayers whose tax year coincides with the calendar year (for other taxpayers the deadline is end of eleventh month after the end of the relevant tax year). There may be situations where you would need to revise an already filed form TPR, such as after you subsequently complete your local file, obtain a benchmark study or verify certain financial disclosures in the form.
In such cases TPR may need to be amended if it is discovered that there are errors in the reported values, cases of misclassification, incorrect indication of the applicable transfer pricing method, differences between TPR and transfer pricing documentation, or changes in related party information.
A TPR is amended by refiling the complete form for the same year, with the purpose of the filing marked as “amendment”. You need to fill in all the information, not just the fields affected by the change. The filing must be signed by your authorised officers or by an agent (attorney-in-fact) with appropriate authority.
In practice, form TPR is usually amended to ensure its disclosures are in line with the local file and current results of comparability analysis.
If this issue pertains to your business and you are interested in our assistance, please contact us.
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