Transfer pricing file- a contextualized Approach. Case Study
Abstract
The transfer price is basically the price used for transfer of tangible and intangible assets between related parties and it should be determined on the basis of market value without being influenced by the relationship of affiliation. However, if for services or tangible assets, the comparison of the transfer price to the market one is relatively easy to achieve, for the intangible ones, quantifying future benefits waived by the affiliated person compared to the situation in which it would be independent is harder to be established.
References
Grigorie, Lăcriţa, N., Boiţă, M., Constantin, E. et. al. (2009). Public Finances and Taxation, Didactic and Pedagogical Publishing House
Grigorie, Lăcriţa, N., Boiţă, M., Constantin, E. et. al. (2008). Accounting regulations compliant with European Directives, Didactic and Pedagogical Publishing House
*** Government Decision no. 529/2007 regarding the procedure for issuing individual in advance tax solution and of the advance price agreement
*** Law no. 571/2003 regarding the Fiscal Code, as amended and supplemented
*** Government Ordinance no. 92/2003 on the Fiscal Procedure Code, republished with subsequent amendments
*** N.A.F.A. President Order no. 222/2008 regarding the contents of the transfer prices file
