Prețurile de transfer (I). Materia prețurilor de transfer, o dublă perspectivă: națională și internațională
Transfer Prices (I). Transfer Pricing, a Double Perspective: National and International
Subject(s): Law, Constitution, Jurisprudence, Law on Economics, EU-Legislation, Commercial Law
Published by: Editura Hamangiu S.R.L.
Keywords: transfer pricing; the arm’s length principle; The Organisation for Economic Cooperation and Development; affiliated taxpayers; taxes; costs; interest; expanses; multinational enterprises;
Summary/Abstract: Without a shadow of doubt, in the matter of transfer pricing (as well), The Organisation for Economic Cooperation and Development presents itself as the Umberto Eco of economic globalisation, while offering a brief yet very important description of the key concepts in this field. Through continuous references of national legal regulations to the rules in the matter dictated by supranational bodies whose continuous concern is guaranteeing an equal fiscal treatment between affiliated and independent taxpayers, the present study is dedicated to explaining the concepts and basic principles in the matter of transfer pricing, imperiously necessary for understanding the phenomenon of business internationalisation: the ”matrix” of transfer pricing. Starting timidly by stating the definition of the key terms, the paper shall continue with highlighting the reason and necessity of regulating the matter of transfer pricing, culminating with a synthesis of all the current national regulations in the area and finding its purpose in the section dedicated to the arm’s length principle as the basis of the transfer pricing matter.
- Issue Year: II/2019
- Issue No: 4
- Page Range: 43-65
- Page Count: 23
- Language: Romanian