Current legal topics, practical advice and analyses from our experts.
The purpose of tax audit is to examine taxpayer's procedures in setting transfer prices, i.e. whether they chose an appropriate transfer method, whether they have sufficient documentation for transactions under review, whether they can transparently explain individual cases.
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Transfer pricing is a dynamically evolving area and it could be said that its legal regulation is not sufficient and unambiguous, which is also reflected in different views on it from the perspective of the tax administrator and the taxpayer.
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The extinction of claims by set-off represents a form of cashless settlement between debtor and creditor, where no real performance occurs between them, which undoubtedly brings cost savings.
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