Across the world, tax authorities are increasingly requiring transfer pricing forms: structured disclosures that obligate taxpayers to actively report related-party transactions, pricing methods, and transfer pricing policies as part of their annual compliance process. These forms have become one of the most important instruments in modern transfer pricing enforcement.
This article explains what transfer pricing forms exist globally, how countries structure them, and why they now play such a central role in audit selection and risk assessment.
What are transfer pricing forms?
Transfer pricing forms are statutory disclosures that require taxpayers to report transfer pricing information directly to the tax authority in a structured format. They focus on factual and quantitative data: which related parties are involved, what transactions occurred, in what amounts, and under which pricing method.
They are fundamentally different from transfer pricing documentation. Documentation explains why prices are arm’s length and provides supporting analysis. TP forms, by contrast, disclose what exists. In many jurisdictions, tax authorities receive this data long before they ever request documentation.
This distinction is crucial. A taxpayer may have perfectly robust documentation, but failure to submit a required TP form can still result in penalties or automatic audit triggers.
More info here in our other Article What are TP Forms?
Why tax authorities have embraced TP forms
From a tax authority’s perspective, traditional transfer pricing documentation has clear limitations. It is unstructured, difficult to analyse at scale, and typically only becomes available once an audit has already started. Audits themselves are costly and reactive by nature.
Transfer pricing forms change this dynamic. By collecting structured data annually, tax authorities can compare taxpayers, identify anomalies, and select audit targets algorithmically. Risk assessment no longer starts with an audit request; it starts with data.
AI and the transfer pricing disclosure question
At first glance, it may seem counterintuitive that tax authorities continue to expand transfer pricing forms at a time when artificial intelligence can increasingly analyse unstructured documentation. In theory, AI could be used to scan Local Files, Master Files, and benchmarking studies directly.
In practice, however, transfer pricing forms remain indispensable. They provide legally enforceable, standardised disclosures that allow tax authorities to compare taxpayers consistently, apply automatic penalties, and select audit targets based on objective criteria. AI may identify patterns, but enforcement still relies on formal declarations made by the taxpayer.
Rather than replacing TP forms, AI is likely to reinforce their importance. Structured disclosures create clean, comparable datasets on which AI systems can operate far more effectively than on heterogeneous, narrative documentation. In modern transfer pricing enforcement, TP forms and AI are complementary tools, not alternatives.
The global landscape of transfer pricing forms
Although the terminology differs from country to country, transfer pricing forms worldwide follow a limited number of recurring models. Understanding these models is far more useful than memorising individual country rules.
The table below summarises the main global TP form models, how they are typically filed, and how tax authorities use them in practice.
| TP form model | How it is filed | What is disclosed | Typical countries | Audit impact |
|---|---|---|---|---|
| Embedded in corporate tax return | Annex or section of the corporate income tax return | Related-party transactions and pricing method | Hungary, Thailand, Turkey, Vietnam | High |
| Standalone TP disclosure form | Separate annual filing, often XML or online | Detailed transaction-level data | Poland, Spain, Russia, Ukraine, Mexico | Very high |
| Summary or simplified declaration | Separate simplified form | Transfer pricing policy overview and high-level transactions | France, Belgium, Greece, Senegal | Medium |
| Informative annex or schedule | Annex to the tax return | Listing of related-party transactions | Finland, Canada, Australia, Czech Republic | Medium |
| No statutory TP form | Documentation obligation only | No upfront disclosure | Netherlands, Germany, Italy | Low, but increasing |
TP forms embedded in the corporate tax return
In many countries, transfer pricing disclosure is embedded directly into the corporate income tax return or its annexes. Taxpayers must report related-party transactions as part of their annual filing, often using predefined data fields.
Because the disclosure forms part of the tax return itself, non-compliance frequently renders the return incomplete. Penalties are therefore applied automatically, regardless of whether the underlying pricing is arm’s length. For tax authorities, this model allows transfer pricing risk assessment to be integrated directly into standard tax processing systems.
Standalone annual TP disclosure forms
Standalone TP forms represent the most enforcement-driven model. These forms are filed separately from the tax return and often require extensive transactional detail, sometimes in machine-readable formats.
In practice, these disclosures are a primary audit-selection tool. They enable tax authorities to analyse pricing patterns across industries, identify loss-making entities with significant related-party flows, and focus audit resources where the risk profile is highest.
For multinational groups, these forms tend to carry the highest compliance risk due to their level of detail and the penalties associated with incorrect or late filings.
Summary or simplified TP declarations
Some jurisdictions require a more high-level disclosure. Instead of reporting every transaction in detail, taxpayers submit a summary of their transfer pricing policy and the main categories of related-party transactions.
Full transfer pricing documentation must still be prepared, but it is only submitted upon request. This approach gives tax authorities visibility over group structures and pricing frameworks while limiting administrative burden for lower-risk taxpayers.
Informative annexes and transaction schedules
In this model, taxpayers attach a schedule or annex to the tax return listing related-party transactions. These disclosures are often less detailed and focus on transaction existence rather than pricing justification.
Although lighter in form, these annexes still play a significant role in audit selection. They allow tax authorities to identify taxpayers with cross-border related-party activity and request documentation selectively.
Countries without a formal TP form
A small number of jurisdictions still rely primarily on documentation obligations without requiring a dedicated TP disclosure form. However, even in these countries, tax authorities increasingly request structured transfer pricing information during audits.
The absence of a statutory TP form should therefore not be interpreted as low transfer pricing risk. In many cases, it simply reflects a lag in formalising disclosure requirements.
A clear global direction
Across regions, legal systems, and levels of economic development, the direction is consistent. Transfer pricing enforcement is moving away from document-centric reviews toward data-driven compliance.
Tax authorities want structured information early, penalties are increasingly linked to disclosure failures rather than pricing adjustments, and audit selection is becoming more automated.
Why this matters for multinational groups
For multinational enterprises, this shift has practical consequences. In many jurisdictions, failing to submit a TP form can be more damaging than submitting imperfect documentation. Tax returns may be considered incomplete, penalties may apply automatically, and audits may be triggered solely on the basis of disclosure data.
Managing transfer pricing compliance today therefore requires more than preparing documentation. It requires maintaining a clear and up-to-date understanding of which transfer pricing forms apply, where they must be filed, and how disclosure obligations differ across countries.
To manage this growing complexity, many multinational groups now rely on automated compliance tooling. In TPGenie, this is addressed through a dedicated Compliance Tracker that continuously monitors transfer pricing legislation by country, alerts users to new or changing TP forms, tracks filing deadlines, and records which transfer pricing forms have been filed for each entity within an MNE group. This allows tax teams to move from reactive compliance to proactive control, reducing the risk of missed filings or outdated obligations.
Final thought
Transfer pricing forms are no longer a peripheral compliance detail. They have become one of the primary mechanisms through which tax authorities monitor, assess, and enforce transfer pricing rules worldwide.
Understanding how these forms work and how they differ across jurisdictions, is now an essential part of global transfer pricing compliance. A full overview of all 2025 TP Forms can be found here.
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