DAŇOVÉ DÔSLEDKY TRANSFEROVÉHO OCEŇOVANIA ZAHRANIČNÝCH ZÁVISLÝCH OSÔB

Abstract

The contribution is focused on current issues and valuation problems of cross-border trade and financial transactions of foreign depandants within international and national taxlegislation Slovak republic. It contains an analysis of the transfer pricing principles such as the independent relation principle, principle of the usual price and the principle of comparability using the tools of functional analysis and risk analysis.  It deals with the methods of transfer pricing needed for setting an independent price and gives details on transfer pricing documentation.The role of transfer valuation is establischment and verification of prices between depandants (personel, capital and otherwice related) entities on the basic of arm´s-length principle. Transfer prices do not arise on the free market, therefore, may vary from the prices agreed between the independent entities. Transfer valuation rules contain the basic methods of transfer valuation, which taxpayers who are doing buseness by transnational corporations should follow. Between the most commonly used transfer valuation methods are traditional transfer valuation methods which are based od comparison of prices and transational profit methods of transfer valuation based on a comparison of profits. The main problem of the application of these methods becomes comparability of prices of comparison subjects. The essential factors are nature of the property or services, functions, risk and economic environment in which the transaction took place.