Analiza de comparabilitate – bazele evaluării prețurilor de transfer. Aspecte teoretice și probleme din practică
Comparability analysis – basis for transfer pricing assessment. Theoretical aspects and practical issues

Summary/Abstract: The preparation of a comparability analysis is a complex process that involves, on the one hand, knowledge of transfer pricing legislation and, on the other hand, the exercise of professional judgement, with the ultimate objective of enabling a correct assessment of compliance with the arm’s length principle in transactions between related parties. There are certain steps that must be followed in preparing a comparability analysis (starting with a thorough understanding of the transaction being tested, identifying potential comparable and filtering them through the five comparability factors, to interpreting the results and stating conclusions), but the process itself is not linear. The sources of comparable information are diverse, but the data used in the analysis must meet certain requirements – it must be objective, credible and accessible to all parties. And while there will always be controversy in practice, it is important that errors are identified and corrected in the future through genuine, open and reasoned dialogue between taxpayers and tax authorities.

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