English to Polish Bus/Financial Law: Taxation & Customs

transfer price evaluation percentage

The transfer price evaluation percentage (TEP) is determined as the outcome of the plan¬ning process in the fourth quarter. This close linkage between planning and the TPM pricing method (stipulation of the transfer price evaluation percentage per VLG) means that profits are channelled directly. The realisation of cost planning is also required. From a tax per¬spective we do not believe there can be objections to this. Nonetheless, we would like to point out that an adjustment of the plan values according to the actual values at the end of the year by means of credit note or subsequent debit would be possible from a tax per¬spective in order to smooth out any fluctuations. At the present time, however, there is a view prevalent in the Federal Ministry of Finance (BMF) which opposes such an adjustment at the end of the year. Tax auditors, however, consistently take the view that a secure ba¬sis for transfer prices is better than a pure planning specification.

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