Transfer pricing

The obligation to prepare and submit documentation on transfer prices in accordance with the Law on Corporate Income Tax began since 2013. This area brings with it significant risks, bearing in mind the conflicting interests on the one hand of the tax authorities to increase their revenues and on the other hand of the multinational companies to reduce their tax obligations. Bearing in mind the fact that the calculated amount of profit tax is based on certain assumptions, such as available data, the company’s strategy and the factors that influenced the formation of the price, it is necessary to point out that transfer pricing is not an exact science and that the key goal is to arrive at a reasonable assessment of profit tax in accordance with the principle of “out of reach”.