Il Tranfer Pricing: la normativa, la determinazione dei prezzi di vendita e l'estensione del concetto di evasione fiscale

Transfer pricing describes the ways in which multinational companies resident in different states and linked by a relationship of control and / or connection, to determine their internal prices of commercial events relate to the sale of goods and provision of services. It can say that in general they go to manipulate business costs. The issue of transfer pricing emerges against the proliferation of the phenomenon of internationalization (typical corporate strategy) with a single economic entity, and a plurality of legal entity simplifying, a parent company and various subsidiaries. The fundamental question that revolves around the issue of transfer pricing is expressed on the issue of the transfer of taxable income from state to state, which, of course, according to a logic of "tax savings" or better known as "avoidance", means that State receiving taxable income is a tax haven. In this context it can be said that the objective of multinational companies is to study and plan the steps to be taken in order to achieve intra-group result Please profit maximization group and optimize the tax burden. It can therefore be argued that the problem of transfer prices in many disciplines, from tax law / corporate / statutory corporate economy and therefore is under the magnifying glass of the Groups and the fiscal authorities. In later chapters, we will analyze the methods of determining the price and as a result national regulations and the OECD intervene in order to combat this phenomenon of price manipulation and to establish the criteria for determining the normal value of intercompany transactions. Lastly, we analyze the consequences of a control by fiscal authorities from transfer pricing and documentation in support of the defense of the company under control.