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Bezpečné prístavy v oblasti prevodních cien so zameraním na rozvojové štáty
Molnárová, Lucia
The issue of transfer pricing is currently one of the most significant tax probems, which needs to be confronted by multinational enterprises and tax authorities all over the world. The determination of transfer prices that is based on the application of the arm´s length principle, together with the administration and control of transfer pricing is often complicated, time-consuming and costly process. Especially for developing countries, many of which experience difficulties with col-lection data and their analysis due to the lack of information regarding comaparable transactions. For this reason, developing countries should consider using the safe harbour concept, at least for smaller taxpayers or in a case of less complicated transactions. This thesis focuses on proposal of safe harbour for selected develo-ping countries in Asia.

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