Why you shouldn't leave the transfer pricing study until the deadline

A nine-month deadline looks like plenty of time. In practice, most companies react late, and by then there is no time left for analysis and comparable data.

min read

09/09/2026

VELA team

Hands with a pen and calculator over financial reports and charts - working on a transfer pricing study

The 9-month statutory deadline doesn't mean preparation can wait

Don't wait until the deadline!

The 9-month statutory deadline may make it seem that you have plenty of time. In reality, most companies react late, and that is when problems arise.

What happens when transfer pricing documentation is prepared late?

there is not enough time for a quality analysis,
the search for comparable data becomes limited,
the cost of preparing the study rises,
if the Study shows that prices were not at arm's length, you are automatically required to correct your tax return and pay default interest on the calculated difference,
which is why stress and risk reach their peak.

What does preparing a quality transfer pricing study require?

Preparing a quality transfer pricing study requires:

a detailed understanding of your business,
an analysis of transactions and functions,
finding comparable market data,
applying the appropriate methods.

A transfer pricing study is not a document made “overnight”

A transfer pricing study is not a document made “overnight”, and the biggest mistake you can make is to put these activities off until later.

To sum up

Ideally, you should have the transfer pricing report at the time your financial statements and tax balance, i.e. your corporate income tax return, are prepared and filed, which is 28 February and 31 March of the current year for the previous year. The Law also requires the report to be submitted to the competent inspector within 30 days of a request, and in any case the final deadline for preparing and submitting the transfer pricing report is 30 September of the current year for the previous year. In addition, do not overlook the fact that if the study is prepared after the corporate income tax return has already been filed, the tax base may have to be adjusted and additional corporate income tax paid if the study shows that transactions between related parties are not in line with market conditions, which can significantly change your financial statements and reported result. That is why you should establish a corporate practice of analysing studies and related-party transactions in good time and making the right decisions on time, thereby avoiding the risk of significant consequences for your business!

For more information, contact VELA Consulting.

If you're not sure whether this applies to you, get in touch and we'll check together.

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Contents

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