Online ISSN 2286-0266
Print ISSN 1223-0685
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Andrei BIRMAN
Academia de Studii Economice din Bucureşti
Olivia CHITIC
Academia de Studii Economice din Bucureşti

“Transfer pricing” mainly represents a fiscal concept which relates to the prices set by a taxpayer when selling to, buying from, or sharing resources with a related party, i.e. those entities that have a common legal and / or economic control, such as multinational enterprises. Due to the significant share of the related parties’ transactions (approx. 60% of the international trade) and due to the importance of multinational financial institutions in the global economy, the transfer pricing area offers a wide range of opportunities for the economic planning of the resources while, in the same time, it assumes a series of fiscal and legal liabilities for the parties involved. The current economic and financial crisis is persistent and generates, on one hand, a decrease of the income collected by the authorities from direct taxes and, on the other hand, it generates pressures for restructuring and increasing the efficiency of the multinational enterprises’ operations. Thus, it is easy to understand why it is a difficult task to analyze if the prices used under related parties’ transactions respect the market value principle and why transfer pricing is on the agenda of fiscal authorities, multinational enterprises, fiscal consultants and of the various economic analysts, generating the imperative of using more and more complex tools of analysis as well as using the economic theories. This article has a theoretical nature but is designed to be also used as a brief guide for approaching the more complex areas of transfer pricing studies, a guide that reveals the need for a multidisciplinary approach integrating various economic theories in order to explain the current economic circumstances. The article is focused on the financial services industry and makes reference to the way in which transfer pricing may be analyzed in case of two practical solutions implemented by the multinational financial institutions in the context of the current economic recession in order to obtain access (or optimize the access) on the credit market.


ŒCONOMICA no. 3/2011
Keywords: transfer prices, economic theory, inflationary expectations, managed tranzactions, credit portfolio selling
JEL: F23, G01, H25, M16
Preţurile de transfer într-o perioadă de recesiune economică – o abordare teoretică şi empirică