TRANSFER PRICING FILE

These regulations are supplemented by the provisions of the Transfer Pricing Guidelines issued by (O.C.D.E.) and the Code of Conduct on Transfer Pricing (EUTPD) published in the Official Journal of the European Union no C176 / 1 of July 28, 2006. These regulations apply for Romanian case, in other cases local regulations will apply.

A transfer pricing file should include information on the affiliated parties such as: legal, operational and organizational structure, general description of the group's activity, business strategies, policies for setting transfer pricing at group level, description of transactions between affiliated parties, general description of functions and risks assumed by affiliated parties as well as methodology of carrying out a comparability study in order to documentconformity of the transactions analyzed with arm`s length principle.

Building a transfer pricing file involves following several steps:
1: Performing a functional analysis of the transaction and establishing the operational profile of the parties involved in the transaction.This is the starting point for establishing the hypotheses of the comparability study to be carried out in step 2.
2: Comparability study starts by establishing research needs regarding the transaction involved and transforming it into a research topic through building research hypotheses, selected sample, model used and research objectives according to the client's needs;
3: Execution of actual research by querying the databases used to test the hypotheses established on step 2.On this stage the comparable variables for the tested party are established, whose transactions regarding transfer pricing are being analyzed;
4: Statistical modeling of data queued from the database according to step 3 together with testingthe selected model and interpreting results obtained according to research objectives represent the economic analysis necessary to document the conformity of the arm`s length principle for the tested transactions;
5: Presenting conclusions of research carried out in the form of a report that documents transfer pricing on the selected transactions, including the economic and functional analysis that form the premises for the comparability study based on which the research hypotheses were based, model used and the research objectives set..

FISCALEX team can assist you in preparing a transfer pricing file in accordance with local and global legislation in the field. We have technical and material capacity for offering qualified service in this field, having thus access to relevant and valid sources of information provided by specialized databases..