The corporate income tax return filing period for the 2025 tax year has come to an end. Attention is now gradually shifting to the 2026 tax year, for which the new transfer pricing documentation rules will apply.

In our previous articles, we presented the key provisions of the new decree and the changes affecting the accounting treatment of transfer pricing adjustments in detail. During the coming period, however, the focus will no longer be primarily on becoming familiar with the rules, but rather on their practical application.

Although transfer pricing documentation only has to be prepared after the tax return has been filed, a number of pieces of information, analyses and internal data will be required that are worth reviewing or collecting during the tax year. Preparing in good time can not only make the preparation of the documentation more efficient, but can also reduce the risk that certain required data or supporting evidence can only be obtained with significant additional effort at a later stage. Below, we take a look at the questions worth considering to ensure appropriate preparation for the 2026 tax return.

Have you already reviewed which related party transactions are affected by the new rules?

The first step is to assess which of the company’s related party transactions are subject to documentation requirements and for which transactions the content or level of detail of the documentation may change.

It is also worth reviewing whether the aggregation of transactions, the applicable thresholds and the related exemptions are being applied correctly under the new rules.

Will the necessary data be available?

The new documentation requirements call for more detailed supporting information in several areas than under previous practice.

It is worth assessing during the tax year from which systems the necessary financial and business information can be obtained, whether additional breakdowns or supporting reports will be required, and whether a clear link can be ensured between the accounting data and the transfer pricing documentation.

Are your current internal processes suitable for meeting the new requirements?

Preparing transfer pricing documentation typically requires the cooperation of several organisational units.

It is therefore worth reviewing whether responsibilities are clearly allocated, whether the necessary information will be available in due time, and whether the economic circumstances supporting the applied pricing can be properly documented.

Do any transactions require more detailed supporting documentation?

For certain types of transactions, the new rules require more detailed analyses and justification.

It is therefore worth reviewing during the tax year whether the documents and business information necessary to properly support the economic substance of the related party transaction, the selected transfer pricing method and the appropriateness of the pricing are available.

Does everyone involved know what information will be required?

Preparing transfer pricing documentation is rarely an exclusively tax-related task. It often also involves the accounting, controlling, legal and business functions.

If these organisational units are already aware during the tax year of what data and information will be required, the preparation of the documentation can generally be carried out much more efficiently.

It is worth preparing during the tax year

The new transfer pricing rules applicable from the 2026 tax year affect not only the format of the documentation, but also require more detailed supporting information and closer consistency between companies’ records, financial data and transfer pricing documentation in several areas.

Preparing in good time gives businesses the opportunity to review their related party transactions during the tax year, refine their internal processes where necessary, and prepare for compliance with the new requirements.

If you would like to assess whether your company is prepared for the transfer pricing documentation requirements applicable from the 2026 tax year, our experts are ready to assist you.