transzferárdokumentáció

transzferárdok, often translated as "transfer pricing," refers to the accounting practice used by multinational corporations to price transactions between their subsidiaries or related entities. These transactions can involve the sale of goods, provision of services, or licensing of intellectual property. The primary goal of transfer pricing is to set a price that is considered "arm's length," meaning it is the same price that unrelated parties would charge for similar transactions in the open market.

The establishment of appropriate transfer prices is crucial for several reasons. Firstly, it affects the allocation of profits and losses among different tax jurisdictions. Each country has its own corporate tax rates, and by manipulating transfer prices, companies can shift profits to lower-tax jurisdictions, thereby reducing their overall tax liability. This practice has led to significant scrutiny from tax authorities worldwide, who aim to ensure that companies are paying their fair share of taxes in each country where they operate.

Secondly, transfer pricing can impact the performance evaluation of subsidiary managers. The prices set for intercompany transactions directly influence the reported profitability of each entity. Inaccurate transfer pricing can therefore distort the assessment of a subsidiary's actual economic performance.

International guidelines, such as those provided by the Organisation for Economic Co-operation and Development (OECD), offer frameworks and methodologies for determining arm's length prices. These typically include methods like comparable uncontrolled prices, resale price method, cost plus method, and profit split method. Despite these guidelines, disputes over transfer pricing remain a common issue between multinational corporations and tax authorities, often leading to complex legal and financial challenges.