Tax authorities are increasingly relying on data analytics, comparing the information disclosed in IFT-2R filed under Article 26(3) of the CIT Act with the data reported in the TPR-C form under Article 11t of the CIT Act. Transactions with related parties – such as royalties, interest, or fees for intangible services – should be reported consistently across both filings. 2026 reports from EY and getsix indicate that data consistency between IFT-2R and TPR-C is becoming one of the priority focus areas for the tax administration.
Three risks worth assessing before year-end closing
- Initiation of verification or tax audit proceedings – discrepancies between IFT-2R and TPR-C may be detected through data analysis conducted by tax authorities.
- Challenge to the WHT rate or exemption entitlement – inconsistent transfer pricing documentation may result in denial of the preferential treatment under a double tax treaty or directive, leading to taxationat the domestic rate.
- Penalties under the Fiscal Penal Code (KKS) – inaccurate data in the filings may be classified as a failure to fulfill reporting obligations, creating risk exposure for the individuals responsible for filing them.
Qualifying groups and Pillar 2
For qualifying groups with revenues exceeding EUR 750 million, the importance of data consistency is even greater. Reporting data for GloBE and Pillar 2 purposes should be consistent with transfer pricing and withholding tax information, creating a coherent overall picture of the group’s tax position.
What to do now
It is worth conducting an internal cross-check of these filings before the tax authority does. Any discrepancy identified by tax authorities before your own review may translate into real financialconsequences.
Contact our team to run a consistency review of your IFT-2R and TPR-C filings before the tax year closes.
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