Compliance Of The Regulatory Framework Of Transfer Pricing In The European Union

In most EU countries, transfer pricing regulations are given within the legislation on corporate income tax. The regulatory framework of transfer pricing in the EU is based on the OECD guidelines on transfer pricing and the Code of Conduct on transfer pricing documentation for associated enterprises in the European Union which sought to standardize the documentation of transfer pricing at EU level. However, Member States can implement additional and more concrete regulation of transfer pricing which leads to a certain disproportionality in the regulation of transfer pricing at EU level. The aim of this study is to ascertain compliance of the European Union with regulatory framework of transfer pricing. The level of compliance is determined on the basis of the following variables: the implementation of the OECD guidelines in the legal framework of transfer pricing, implementation of methods for determining transfer prices, possibilities of implementation and regulation of advanced pricing arrangements, and the existence of specific additional requirements for transfer pricing documentation. The research results show that in the European Union there is a high degree of compliance with the regulatory framework of transfer pricing.