Dokumentacja cen transferowych

Podatnik podatku dochodowego zawierający transakcje z podmiotem krajowym lub podmiotem zagranicznym powiązanym z tym podatnikiem, gdy wartość ww. transakcji przekracza określone w ustawie limity, ma obowiązek sporządzenia odpowiedniej dokumentacji cen transferowych.

Obowiązek przedstawienia dokumentacji dotyczy transakcji, w których wynikająca z umowy lub rzeczywiście zapłacona łączna kwota (lub jej równowartość) wymagalnych w roku podatkowym świadczeń przekracza równowartość: 100 tys. euro – jeżeli wartość transakcji nie przekracza 20 proc. kapitału zakładowego (określonego tak jak dla potrzeb tzw. niedostatecznej kapitalizacji); 30 tys. euro – w przypadku świadczenia usług, sprzedaży lub udostępnienia wartości niematerialnych i prawnych, albo 50 tys. euro – w pozostałych przypadkach. Obowiązek sporządzenia dokumentacji obejmuje też transakcję, w związku z którą zapłata należności dokonywana jest na rzecz podmiotu mającego miejsce zamieszkania, siedzibę lub zarząd na terytorium lub w kraju stosującym szkodliwą konkurencję podatkową, jeżeli wynikająca z umowy lub rzeczywiście zapłacona łączna kwota wymagalnych w roku podatkowym świadczeń przekracza równowartość 20 tys. euro.

Ustawodawca nie określił urzędowego wzoru dokumentacji podatkowej, wskazał jedynie jej konieczne elementy, które mają określać:.

Ustawodawca nie wprowadził szczegółowych zasad prezentacji powyższych informacji, pozostawiając w tym zakresie swobodę podatnikowi. Jednak dokumentacja ma uzasadniać poziom przyjętej ceny transferowej. Dokumentacja spełnia funkcję informacyjną i ma ułatwić organom podatkowym lub organom kontroli skarbowej sprawdzenie osiągniętych przez podatnika dochodów i ustalenia ich na poziomie rynkowym.
Sankcją za nieprzedstawienie dokumentacji na żądanie organów podatkowych w ciągu siedmiu dni od dnia doręczenia żądania jest możliwość zastosowania 50-proc. stawki podatku dochodowego w odniesieniu do określonej zaległości związanej z ustaleniem cen przez podmioty powiązane odbiegających od rynkowych. Krótki termin ustawowy na sporządzenie dokumentacji powoduje w praktyce konieczność sporządzania jej z wyprzedzeniem najczęściej w terminie sporządzenia zeznania za rok podatkowy.

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