Criterii de selecţie a celei mai potrivite metode de documentare a preţurilor de transfer. Metode tradiţionale vs. metode tranzacţionale
Selection criteria of the most appropriate transfer pricing documentation method. Traditional methods vs. transactional methods

Summary/Abstract: This article aims, on the one hand, to outline the minimal legal/theoretical framework regarding the analyzed issue and, more importantly, to present several controversies derived from practice, related to this legal/theoretical framework, which is constituted, in fact, as an argument for what we claim should be applied in practice, contrary to the position sometimes supported by the tax authorities.Therefore, the theoretical framework, respectively the description of transfer pricing methods, has the role of introducing the readers to the sphere of problems. Forward, the article debates several contradictory aspects in the approach and application of transfer pricing documentation methods, outlining the solutions identified in the practice of fiscal inspections, respectively the solutions pronounced in the courts, or at the administrative level.

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