TAX REGULATION ON COST SHARING AGREEMENTS OF BETWEEN THE MULTINATIONAL CORPORATIONS AND ITS AFFILIATED COMPANIES - COMPARATIVE LAW REVIEW
Agreements of multinational corporations (MNCs) how to share the costs between the headquarters and affiliates in creation of the tax planning strategy is the essence of this paper. These agreements have being analysed form the comparative law perspective, in selected OECD member states. Transfer prices are amongst the significant aspects of international taxation and transfer of technology and foreign investments made by the MNCs. The paper has being focused on the aspects of payment to the other affiliated companies in the group for intercompany services rendered, that is the special interest of tax authorities around the world. Nowadays, the primary focus of transfer prices transactions audition MNCs and theirs affiliates performed by the national tax authorities moved from the production towards services, especially financial services (e.g. banking, insurance) since the rising tax avoidance and evasion in this area. It seems that there is a reached consensus agreement in the fled of international taxation that the traditional mechanisms of the tax law applied on transfer prices taxation in the process of resolving tax disputes did not give adequate results. National tax system are struggling with the phenomenon of tax prices since the introduction of value added corporate taxation, wince the transfer prices inﬂuence the allocation of taxable income of the taxpayer – MNCs, between the different tax jurisdictions.