Úpravy převodních cen v hlášení Intrastat

Transfer pricing adjustments in Intrastat reporting

Further to our previous alert HERE, we would like to draw your attention to a relating change concerning the adjustment of transfer prices and their reporting in Intrastat reports.

Previous versions of the Handbook did not contain any information on this area. Thus, it was necessary to follow the general rules for correcting errors and inaccuracies. This process often required detailed administrative work and generated additional costs.

The updated version of the Handbook valid for 2024 and the accompanying information revises this area. According to the new rules, “retrospective price adjustments (e.g.) between a central enterprise and production or sales units in a group made using credit notes or debit notes issued for the difference between the expected profit (including the profit margin) and the achieved profit, usually carried out at the end of the calendar quarter by a single amount, are not reflected in Intrastat”.

From the accompanying information, the problematic passage stating that "this represents an adjustment of profit only, not an actual change in the value of the goods supplied", which was against the argumentative logic for both income tax and VAT, was deleted. However, it remains in the Handbook.

If we ignore this discrepancy, it will still be necessary to distinguish whether the change in the taxable amount is triggered by an adjustment in profitability for income tax purposes or by any other title to which, on the contrary, the general procedure for corrections of errors and inaccuracies applies. Making accurate decision on the various types of discounts, bonuses, and price adjustments, may be difficult.

If you have any questions, please contact the authors of this article or the EY advisory team you are working with.

Authors:

Ivana Krylová

Ivana Svobodová