Viitorul prețurilor de transfer în dreptul fiscal al Uniunii Europene
The Future of Transfer Pricing in European Union’s Tax Law

Summary/Abstract: Transfer pricing represents a significant part of the OECD’s BEPS project and it has been used by multinational companies to avoid the taxation of their profits by transferring their property to their subsidiaries established in low-tax jurisdiction countries. Throughout the decade, international organizations, such as the OECD and specific institutions within the EU, such as the Joint Transfer Pricing Forum, worked tirelessly to develop adequate solutions to the issue that a lot of countries’ tax administrations and authorities have faced with. The Court of Justice of the European Union has issued a judgment recently, leading to a potentially new interpretation of Article 49 of TFEU with regards to transfer pricing. Lastly, the EU Council Directive 2011/16 on administrative cooperation in the field of taxation will also affect the tax assessment procedures between EU member states.

• Details
• Contents