TRANSFER PRICING: GENERAL MODEL FOR TAX PLANNING
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All MNEs generate their revenues through a business model which have a certain organization of functions performed, assets used and risks assumed. Nevertheless, the changes in economic environment have resulted into the situation, when all governments have been increasingly focused on raising revenues through taxation and conversely many MNEs have been focused on decreasing of their taxable business income with using various means. One possibility how to achieve it for both sides is a transfer pricing. The aim of the paper is to create a general model, under which the MNEs could decide for the best business model within the frame of the tax planning, but which would also enable to quantify the impacts on the state budget resulting from that tax planning strategy. Furthermore, the general model determinates more accurate arm's length transfer prices in the business model with respect to recommendations in OECD TP Guidelines, particularly functional and comparability analysis.
597 – 617
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