Noţiunile de ajustare şi de estimare a preţurilor de transfer. imprecizii si efecte

dr. NATALIA SVIDCHI*

* e-mail: natalia.svidchi@e-uvt.ro

Asistent cercetător - Facultatea de Drept, Universitatea de Vest din Timişoara

Avocat - Baroul Timiş

ABSTRACT

Taxpayers who carry out transactions with affiliate parties are familiar with the effects of transfer pricing adjustment and estimation procedures: the determination of the transfer prices at the median, i.e. at the value configured by the central trend of the market. How many of the them wonder, however, if the transfer prices were adjusted or estimated by the tax audit? In practice, within the tax audit documents, tax auditors use the notions of adjustment and estimation of transfer prices in a substitutable way or even together. A possible cause would be represented by the takeover of the wording from the regulatory documents that determine the model and content of certain forms. Another explanation is, however, that the tax auditors do not...