Tax implications of transfer pricing use. Transfer pricing regulation in the world, European union and Republic Croatia

      Аннотация: Transfer pricing in related party transactions, represents one of the hottest areas in the multinational tax management and tax evasion. It?s different from prices that are arranged between unrelated companies. TP are used in profit transferring for minimizing tax burdening and maximizing consolidated profits. In 1995. OECD established TP guidelines for multinational companies and tax administrations. The major possibilities for TP strategies are in the field of intangibles, intra - group services, business restructuring and tax havens. Worldwide, the focus is on their audit and control (North and Latin America, Asia - Pacific). Developing countries consider preconditions that they must satisfy for successful implementation of TP legislation. In the EU Joint TP forum works on consensus principle in order to resolve transfer pricing practical problems. The EU legislation has prescribed structure of harmonized documentation. Elimination of it?s effects on EU level was attempted to be resolved by adopting consolidated corporate tax base. Transfer prices can?t be cancelled, so the problem globally still exists and because of it?s nature, it represents more ?art? than an exact science.

Ключевые слова: Transfer Pricing, associated companies, OECD Guidelines, documentation, the arm?s length principle, Double Taxation, Tax Evasion, mutual agreement procedure