Transfer pricing adjustment up 18 pct in 2014
Tax inspectors conducted last year 130 tax inspections which included an analysis of the affiliation relations of the taxpayer and the transfer prices applied as part of the transactions undertaken with the identified related parties, says Transfer Pricing Services (TPS).
“Last year were conducted a third of the total number of transfer pricing inspections performed until present, and the biggest transfer pricing adjustment performed by the tax inspectors was 18 percent higher than the one performed in 2013. The adjustment was performed to a large taxpayer not named by NAFA,” reads a TPS informative note on official data regarding the activity undertaken by the National Agency for Fiscal Administration (NAFA) in the area of transfer pricing over 2014.
According to TPS, NAFA mentions that the team allocated for managing the area of transfer pricing consists of 54 tax inspectors at local level and 12 tax inspectors at the central level. To date, 72 tax inspectors were trained as part of an experience exchange program with experts from UK, and 196 tax inspectors operating in the territory participated last year in intensive training seminars in the area of transfer pricing. According to an official note from 2014, all tax inspectors within the tax inspection apparatus of NAFA have attributions in auditing transfer prices, by way of requesting the transfer pricing documentation file.
