Examples of using Transfer prices in English and their translations into Polish
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Starbucks groups(so-called"transfer prices") that do not correspond to market conditions.
how to document them in order to manage the transfer prices effectively and minimize the tax risk.
as set out in the Annex, and consider it as a basic set of information for the assessment of a multinational enterprise group's transfer prices.
For the purposes of this report the‘audit phase' starts with the decision to make a serious commitment of a tax administration's resources to concretely investigate whether transfer prices were set in accordance with the arm's length principle.
i.e. the“EU TPD” referred to in the Annex, and consider it as a basic set of information for the assessment of a multinational enterprise(MNE) group's transfer prices.
services sold between companies in the Fiat and Starbucks groups(so-called‘transfer prices') that did not correspond to market conditions
Since the EU TPD is a basic set of information for the assessment of the MNE group's transfer prices a Member State would be entitled in its domestic law to require more
This claim could not be accepted since the profit margin realised by the related importer is based on transfer prices between associated parties(the company in question
loss for the supplier, the raw material prices were considered to be unreliable transfer prices.
aspects of tax and inspection proceedings regarding transfer prices and of instruments limiting the tax risk.
to obtain sufficient information for the assessment of a group 's transfer prices; the possibility of centralization of the core part of the documentation( the" masterfile")
to obtain sufficient information for the assessment of the MNE group 's transfer prices,( ii)transfer pricing information relevant for all EU affiliates of a multinational enterprise.">
the trade in proprietary interest within vertically integrated utilities shall be subject to an obligation to verify transaction prices in terms of transfer prices.
In this way the taxpayer is certain that the transfer price in transactions covered by the agreement shall not be questioned.
conferences and discussion forums in the area of taxation(transfer pricing in particular) and he is the author of press articles on tax issues.
To see the transfer price, choose the departure point(town,
as well as changes in transfer price regulations will also be discussed.
Get in touch with us Transfer pricing Our transfer pricing clients can access to our benchmarking studies, which we have
participating in tax audits, and preparing transfer price documentation.
that proposition allows a degree of judgment about the level of evidence that is required to evaluate a transfer price and to ascertain that a particular method is a reasonable estimation of an arm's length price OECD 1.12-1.13 and 1.68-1.69.