Съответствие с принципа на независимите пазарни отношения в контекста на трансферното ценообразуване – насоки за изследване
Principle of Independent Market Relations Compliance in the Context of Transfer Pricing – Guidelines for Research

Author(s): Desislava Yosifova, Kiril Angelov
Subject(s): Economy, Accounting - Business Administration
Published by: Университет за национално и световно стопанство (УНСС)
Keywords: principle of independent market relations; transfer pricing; multinational economic groups; related and independent persons
Summary/Abstract: The principle of independent market relations is an international standard in transfer pricing applied by OECD member countries (Organization for Economic Co-operation and Development) to multinational economic groups for tax purposes.The OECD model of double taxation avoidance agreements requires the definition of independent market relations by the OECD, which forms the basis of bilateral double taxation agreements adopted by OECD member countries, as well as a growing number of non-member countries.This principle ensures equality in the tax treatment of multinational companies and independent enterprises. It lays down an equal footing in terms of tax objectives for related and independent entities. It prevents the creation of tax advantages or adverse effects that would otherwise distort the relative competitive positions of the two groups of tax subjects.

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