Short Reflections about the Transfer Pricing File

Substantive development of the international trade over the past 20 years, reflecting to some extent the degree of integration of national economies and technological progress, presents tax issues of increased complexity in the determination of income and expenses of a company or of a permanent establishment which is part of a multinational group and which must be approached within a jurisdiction. In principle, the specific the right of taxation of each state depends mostly on the tax system used by it: if it is a tax system based on tax residence, source of income, or both. In applying those principles in taxation of multinational companies, one of the most difficult problems encountered consists in establishing, for tax purposes, the appropriate transfer pricing. Taking into account the phenomenon of internationalization of the economic crimes, this paper aims treat uniform the subject in question, but with references to certain mandatory provisions contained in the OECD Guidelines regarding of the transfer pricing.