Transzferárgyakorlatok

Transzferárgyakorlatok refers to the pricing of goods, services, or intangible assets transferred between related entities within a multinational enterprise. These transactions, often occurring between parent companies and their subsidiaries or between sister companies, require careful consideration to comply with tax regulations. The fundamental principle is that these intra-group transactions should be priced as if they were conducted between independent parties in an arm's-length transaction. This "arm's length principle" ensures that profits are recognized and taxed in the jurisdictions where the economic activity generating those profits actually occurs.

Tax authorities closely scrutinize transzferárgyakorlatok to prevent profit shifting, where companies artificially shift profits to lower-tax jurisdictions. Companies must therefore establish and document their transfer pricing policies, which typically involve selecting a transfer pricing method. Common methods include the comparable uncontrolled price (CUP) method, resale price method, cost plus method, 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.

Maintaining robust documentation is crucial for defending transfer pricing policies. This documentation typically includes a description of the intra-group transactions, the functional analysis of each entity involved, the economic analysis supporting the chosen transfer pricing method, and the pricing outcomes. Regular review and updates of transfer pricing policies are also necessary to reflect changes in business operations, market conditions, and tax laws. Failure to comply with transfer pricing regulations can result in significant tax adjustments, penalties, and interest.