Prețurile de transfer (III). Documentația justificativă a prețurilor de transfer. Obligația de întocmire a dosarului prețurilor de transfer și apusul ei în fața acordului de preț în avans
Transfer Pricing (III). The Transfer Pricing File. Obligation to Prepare the Transfer Pricing File and Its Back-Drop Before the Transfer Pricing Ruling

Summary/Abstract: The last part of the transfer pricing trilogy shows a more technical side of the matter, analysing the rules regarding documentation on transfer pricing, divided in two major sections: one dedicated to the transfer pricing file and the one regarding the advance pricing agreement. There will be, however, a preliminary discussion on fiscal and accounting records, the starting point of everything that involves documentation in tax matters. The paper regains its dynamic character in the third section dedicated to the advance pricing agreement, culminating in the detailed presentation of a case that is representative to the European transfer pricing – the Court of Justice of the European Union’s judgment in case Hamamatsu Photonics Deutschland GmbH v. Hauptzollamt Munich, which discusses the implications that the tax authority’s adjustments on the transactions involving associated parties have on the determination of indirect taxes (customs duties).

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