Transfer Pricing Documentation - A Current Issue

Abstract

Rather quick development of the business environment has led to the implementation of legislative measures to meet the requirements and amendments thereto. With the adoption of the Fiscal Procedure Code and Order no. 442/2016 were founded transfer pricing procedures, denoting a means of making taxable transfer of a high tax country to a low tax country. These laws have laid down conditions that must be met and materiality thresholds that must take into account the taxpayer to draft transfer pricing documentation file. The aim of these measures is to reduce the differences between the prices charged by the related parts and the market value and also to actual results of company taxation. The tax authorities are entitled to apply price adjustments when it is not the principle of market value, which entail economic double taxation. Application and dossier preparation of transfer pricing contribute to a collective vision on the market in which the company operates, understanding how business development and, not least, the creation of an appropriate fiscal planning