Transfer prices between related companies must reflect market conditions, not internal profit-allocation priorities. A publication by Nermin Sefić.
Transfer prices between related companies must reflect market conditions, not the group's internal priorities for allocating profit.
Transfer prices between related companies must reflect market conditions, not the group's internal priorities for allocating profit.
When companies within the same group operate across multiple jurisdictions, the price one company charges another for a service or good must reflect terms two unrelated parties would agree — the so-called arm's-length principle. Deviating from that principle, even unintentionally, opens the question of income reclassification by tax authorities in multiple countries simultaneously.
Documenting transfer-pricing methodology before the transaction, rather than afterward as a defence during an inspection, reduces exposure to double taxation and penalties. Regularly reviewing that documentation in line with changes to the group's business model is just as important as setting it up initially.
Cjelovit tekst i izvor: https://gnk-asg.hr/en/publications/cross-border-taxation-transfer-pricing/
Autor i urednička odgovornost: Nermin Sefić. Izdavač: GNK ASG d.o.o..
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