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Following the publication of Administrative Instruction MF No. 02/2017 on Transfer Pricing which sets out rules and procedures for the implementation of the transfer pricing provisions of Law No. 05/L-029 on Corporate Income Tax, the Tax Administration of Kosovo has published an announcement for the submission of the annual controlled transactions notification as per the template provided in the Administrative Instruction.
Although the Administrative Instruction become effective in July 2017, according to the announcement of the Kosovo Tax Administration, the obligation for submission of the annual controlled transactions notification will be applied retrospectively, i.e. from 2016.
The notification on controlled transactions (i.e. the summary of all the cross-border transactions between related parties) for the year 2016 should be submitted in hard copy not later than 30 November 2017 to the Division for Transfer Pricing of the Tax Administration in Kosovo. Considering the above, Kosovo taxpayers may need to prepare the local transfer pricing file also for the related party transactions of 2016.
The deadline mentioned above relates only to 2016, while for other upcoming years the deadline for submission of the notification on annual controlled transactions will be 31 March of the following year of reporting.
We would be delighted to share with you more information about the transfer pricing provisions during our Business Seminar which will be held on 12 October 2017 at Sirius Hotel, Pristina.
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