Abstract:

The article deals with the theoretical side of the transfer pricing issue. Based on the globalization trends and related changes in legislative, transfer pricing is the current topic. Until 2015, transfer pricing was an unknown term within smaller enterprises doing business across the territory of the Slovak Republic. Since 2015, the obligation to keep documentation for transfer pricing has begun to apply also to smaller enterprises doing business only in the Slovak Republic. Since then, the legislation in the field of transfer pricing has been changed. It can be stated that transfer pricing is subject to international regulations, which also apply in Slovakia. The aim of the contribution is to present transfer pricing issue as a tool for eliminating the purposeful influence of the tax base. Authors dealt with the theoretical background of transfer pricing issue, as well as the determination the usual price on the market and compare it with the transfer price between related entities focusing on committing transfer pricing rules.

The article contains the historical development of transfer pricing, definitions of basic terms as well as methods usable in the process of transfer pricing. The practical part presents a model of the use of transfer pricing as a tool for the tax base influence elimination.