Ceny transferowe a ryzyko podwójnego opodatkowania

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.