The Useless Of The Transfer Pricing File

In the context of the globalization and of the strengthening of the relations between the UE economical agents, it appears more and more the idea of groups of entities for the justification of the reciprocal deliveries, buying and loans. The transferring price is a concept that requires maximum attention from the affiliated parts, meaning the entities with reciprocal operations and common managers or associates. The theme of our study is the verification of the hypothesis when the transferring price documentary file is not useful. The research methodology of our study include: dedicated literature, study cases, etc. the conclusion is that all affiliated entities (according to the national legislation) are legally imposed to establish such a documentary file and the tax authorities may require explanations and information related to the content of this file. Still, the file does not bring extra information for the tax authorities, because its establishing is partial from the start, because no tax payer will accuse himself in front of the tax authorities. We propose the elimination of this documentary file and its replacement with an electronic format of information to an international level, so the tax authority can perform an analysis of the intra-group operation without going to the premises of the economical operators