Prețurile de transfer. Serviciile intra-grup: între deductibilitate și respectarea principiului valorii de piață
Transfer pricing. Intra-group services: between deductibility and compliance with the arm's length principle

Summary/Abstract: From the perspective of transfer pricing issues, the transfer pricing methods mentioned in Article 11, paragraph (4) of Law no. 227/2015 on the Fiscal Code ("Fiscal Code") are applicable for determining compliance with the arm’s length principle for all categories of transactions with affiliated persons, regardless of their nature (e.g., tangible assets, intangible assets, services, financial transactions, etc.). These methods include: the comparable uncontrolled price method, the cost plus method, the resale price method, the transactional net margin method, the profit split method, as well as any other method recognized in the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations ("OECD Guidelines").

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