What is Voluntary self-adjustment of transfer pricing?
A taxpayer's own correction, without waiting for tax control, of a case where a price set for a related party that differs from the market price reduced the amount of tax or increased a loss. Article 177 of the Tax Code gives the taxpayer the right to do this (it does not oblige them). The adjustment is made after the end of the calendar year that includes the relevant tax periods. Legal entities do it within the deadlines for filing the corporate profit tax return, and individuals within the deadlines for filing the annual income declaration. Which transaction was adjusted is stated in the explanation attached to the amended return. If the adjustment results in unpaid tax, it is paid no later than the date on which corporate profit tax (for individuals, personal income tax) for that period is due; no late-payment interest is charged for the period up to that date. The basic concept of the transfer price is covered in a separate term (transfer price).
Source: Soliq kodeksi, 177-modda; Soliq kodeksi, 176-modda