As global tax authorities intensify their scrutiny of intercompany transactions, staying on top of transfer pricing deadlines across the EU is more critical than ever. With varying submission requirements, formats, and thresholds, multinational enterprises (MNEs) operating in the European Union must navigate a complex compliance landscape.

This 2024 update outlines the major transfer pricing documentation deadlines across EU countries, ensuring your organization meets requirements under OECD-aligned transfer pricing methods and local transfer pricing regulations.

Why Transfer Pricing Deadlines Matter

Missing a deadline isn’t just a clerical error—it can trigger penalties, audits, and transfer pricing adjustments. As more jurisdictions enforce strict transfer pricing documentation rules under the arm’s length principle, companies must ensure they’ve covered all bases:

• Accurate application of transfer pricing techniques
• Alignment with functions, assets and risks (FAR)
• Timely reporting of controlled transactions and party transactions
• Submission of master files, local files, and Country-by-Country Reports (CbCR)

Key EU Transfer Pricing Deadlines in 2024 (by Country)

Austria

• Local File & Master File: Must be prepared contemporaneously and submitted upon request (generally within 30 days).
• CbCR: Due within 12 months of the fiscal year-end if group turnover > €750M.

Belgium

• Master File (Form 275 MF): Filed with the corporate income tax return, if group revenue exceeds €50M.
• Local File (Form 275 LF): Filed with return if intragroup transactions exceed €1M.
• CbCR (Form 275 CBC): Due 12 months after fiscal year-end for MNEs exceeding €750M in global turnover.

Czech Republic

• Local File: Required only if transactions with related parties exceed statutory threshold; submitted on request.
• Master File & CbCR: Required if conditions of the OECD threshold (€750M) are met.

France

• Local File: Submitted within 6 months of corporate tax filing (if revenue > €400M).
• Master File: Required under same thresholds.
• CbCR: Due within 12 months of the fiscal year-end.

Germany

• Local File & Master File: Must be submitted within 60 days of request.
• CbCR: Due 12 months after fiscal year-end.

Italy

• Local File: Must be digitally signed and timestamped before the tax return is filed. Applies if revenue > €50M.
• Master File: Maintained and provided upon request.
• CbCR: Submitted 12 months after fiscal year-end.

Netherlands

• Master File & Local File: Mandatory for Dutch entities if consolidated revenue exceeds €50M; to be retained and submitted upon request.
• CbCR: Required within 12 months if the MNE group exceeds €750M in turnover.

Poland

• Local File: Required if annual transaction value exceeds PLN 10M (goods) or PLN 2M (services).
• Master File: Needed if consolidated revenue > €200M.
• CbCR: Filed within 12 months.

Spain

• Local File & Master File: Mandatory if revenues exceed €45M; must be submitted within 6 months and 25 days after fiscal year-end.
• CbCR: Required within 12 months if global revenue exceeds €750M.

Common Filing Elements Across the EU

Despite variations in transfer pricing methodology and documentation thresholds, most EU countries follow OECD’s transfer pricing guidelines:

• Standard CbCR threshold: €750M in global turnover
• Preference for one-sided methods: transactional net margin method, cost plus method, or resale price method
• Supporting documentation must demonstrate adherence to the arm’s length transfer pricing standard using reliable comparable uncontrolled transactions
• Functional analysis of functions, assets and risks is essential to identify the tested party and appropriate pricing method

Key Observations for MNEs

1. Deadlines Are Shorter Than You Think

Several jurisdictions, such as Germany and Austria, enforce tight 30–60-day response windows after a request from tax authorities. Be proactive.

2. Thresholds Vary Substantially

Belgium and Italy apply €50M thresholds for full documentation, lower than OECD’s €750M CbCR requirement. Know your obligations per country.

3. Timing, Format, and Language Are Crucial

Some tax jurisdictions require local language submissions or e-filings. Failing to comply on format alone can result in rejections.

4. Comparability is King

Inappropriate benchmarking can jeopardize your defense. Whether applying the profit split method or CUP method, ensure you capture accurate gross profit margin, net profit, and price charged.

How Reptune Helps You Stay Deadline-Compliant

Reptune empowers MNEs to:

• Automate local file, master file, and CbCR generation
• Monitor real-time filing status across EU jurisdictions
• Align your transfer pricing techniques with each entity’s functions, assets and risks
• Store historical submission data to defend future audits
• Benchmark uncontrolled transactions using robust, built-in databases

Conclusion

2024 is a year of heightened scrutiny. EU jurisdictions are not just harmonizing with OECD rules—they’re enforcing them stringently.

MNEs must ensure their transfer pricing documentation aligns with local rules, is defensible under the arm’s length principle, and meets every transfer pricing deadline.

With Reptune, companies can meet every obligation across jurisdictions—on time, every time.

Ready to future-proof your compliance across the EU?

Book a demo with Reptune and confidently manage your 2024 transfer pricing calendar.