In the issue 64/13.08.2019 of The State Gazette, the Law on the
Amendment and Supplementation of the Tax and Social Insurance
Procedure Code (TSIPC) has been promulgated. A new Chapter 8 A has
been created and it specifically introduces rules for the
preparation of transfer pricing documentation.
The Transfer Pricing documentation should be prepared to
demonstrate the nature of commercial and financial relationships of
the taxpayer with related parties. This obligation is in force in
the existing TSIPC but there were no clear and specific rules about
the means of proof and the necessary content.
As of 01.01.2020, the documentation must provide that the
conditions of commercial and financial relationships between
related parties are compliant with the arm's length principle.
Specifically: " the conditions that would be established
between independent persons in comparable circumstances " the
transactions were carried out at market prices
