Transzferárdok

Transzferárdok, often translated as transfer pricing, refers to the accounting and tax practices used by multinational corporations to set prices for goods and services exchanged between their own subsidiaries located in different countries. These internal prices are not determined by market forces in the same way as transactions between unrelated parties. Instead, they are established by the parent company to reflect the value of the goods, services, intellectual property, or financing that flows between its affiliates.

The primary purpose of transfer pricing is to allocate profits and expenses among different jurisdictions. This allocation can significantly impact the tax liabilities of the various subsidiaries and, consequently, the overall tax burden of the multinational corporation. By setting prices strategically, companies can shift profits to countries with lower corporate tax rates and expenses to countries with higher tax rates.

International tax authorities closely scrutinize transfer pricing practices. They aim to ensure that companies are not using artificial pricing arrangements to evade taxes in their respective jurisdictions. The principle of "arm's length" is central to transfer pricing regulations. This principle dictates that the price set between related entities should be the same as if the transaction had occurred between independent, unrelated parties in comparable circumstances. If tax authorities deem that transfer prices are not at arm's length, they can adjust the prices and reassess the tax liability, often leading to penalties and interest. Various methods, such as comparable uncontrolled price, resale price, cost plus, and profit split methods, are employed to determine arm's length prices.