Transferárszabályozás

Transferárszabályozás refers to the set of rules and regulations governing the pricing of goods, services, and intellectual property exchanged between related entities within a multinational enterprise. These related entities, often parent companies and their subsidiaries or sister companies, are legally separate but economically interconnected. The core principle of transfer pricing is the "arm's length principle," which dictates that transactions between these related parties should be priced as if they were conducted between independent, unrelated parties in comparable circumstances.

The primary objective of transfer pricing regulations is to prevent tax base erosion and profit shifting. Multinational enterprises might manipulate transfer prices to allocate profits to low-tax jurisdictions, thereby reducing their overall tax liability in higher-tax countries. Tax authorities implement transfer pricing rules to ensure that each country receives its fair share of tax revenue based on the economic activity occurring within its borders.

Compliance with transfer pricing regulations typically involves extensive documentation. Companies are required to prepare transfer pricing studies that analyze the intercompany transactions, justify the chosen pricing methods, and demonstrate adherence to the arm's length principle. Common pricing methods include comparable uncontrolled price (CUP), resale price method (RPM), cost plus method (CPM), transactional net margin method (TNMM), and profit split method. The choice of method depends on the nature of the transaction and the availability of comparable data. Failure to comply can result in significant tax adjustments, penalties, and double taxation.