THE FINANCIAL TRANSACTIONS BETWEEN RELATED ENTITIES WITH EMPHASISIS ON TRANSFER PRICING

Pricing of intra company transactions has become a major concern of Multinational Corporations’ management. The price used to transfer goods and services between related entities is referred to Transfer Pricing and it is a well-known practice in the field of financial management in the International Businesses. The income shifting activities through price manipulations are limited by tax authorities and regulated with the concept called arm’s length principle. This principle requires the intra company charges to be defined at the same conditions which might set up wile transacting with independent parties. The Transfer pricing (TP) concept and arm’s length principle in the world literature and practices are well known concept, whereas in North Macedonia this is a new an unexplored topic, which legally was regulated in Income Tax law after 2011 year. The research approach used in the study is qualitative. A direct observation of one case company engaged in service industry was done. The objective of this research is to understand the importance of TP issues and implementation processes in corporate level. Additionally, two types of semi structured questionnaires were designed and distributed to the company representatives and TP experts with the main goal to gain additional insights on how professionals are assessing TP importance, and to compare the TP issues between the professionals in the field and managers of the companies.

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