Wycena i dokumentacja transakcji między podmiotami powiązanymi w świetle obowiązujących przepisów
Valuation and documentation of related party transactions in the light of legal regulations

Summary/Abstract: In the contemporary world an increasing proportion of world trade consists of transfer of goods, intangibles and services within multinational enterprises. The problem of transfer pricing has assumed greater importance since the time when legal obligation of transfer transactions documentation was imposed. Transfer pricing might be the instrument used to maximize the group of companies total profit because the choice of transfer prices affects both the division of the total profit among the parts of the company and tax liabilities. Governments take action to ensure that taxpayers do not escape their tax liabilities. To determine tax liability in each jurisdiction, the right price (arm’s length price) has to be applied. In the article the rules of transfer pricing documentation are described and attention is drawn to the obstacles which are difficult to overcome in practice. Examples of transactions within related companies and valuation methods have also been presented, as well as problems with the application of the arm’s length principle.

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