Abstract:
This paper aims to analyze the tax consequences of transfer pricing between
associated enterprises in cross-border transactions. The income adjustment
made in only one country can result in international economic double taxation
of the transferred part of income, that is both at the level of enterprise whom the
income has been attributed to and at the level of the associated enterprise. The
risk of double taxation is essentially lowered, although not always eliminated,
in transactions between associated enterprises from EU Member States, for
the possibility of the corresponding adjustment to income in the other country
where the transferred income had been actually taxed.