Sustainability of Public Finance through the Lens of Transfer Prices and Their Associated Risks: An Empirical Research

At a time when the world economy is being affected by the COVID-19 pandemic, we are more aware than ever of the importance of the sustainability of public finances. This paper outlines its importance by discussing transfer prices and their fiscal associated risks. In the current economic context, marked by the crisis and by an increasing pressure from the control authorities on companies, no matter how important the theoretical research, it cannot capture very well the pulse of practical activity. Under these conditions, empirical studies are becoming increasingly important, requiring an approach to practical economic reality. In order to analyze the way in which companies that carry out transactions with affiliated parties approach the transfer prices and the risks related to them, we conducted an empirical, quantitative research using the CAWI method (Computer Assisted Web Interviewing) and the questionnaire. The research results demonstrate an awareness by the responding companies of the importance of transfer pricing and their risks, the transactions most prone to control in this area being those of financing within the group, followed equally by management services, consulting, assistance and transactions with goods. In the face of legislation that leaves room for interpretation and a high number of controls on transfer pricing, a small number of companies participating in the research have used the Advance Price Agreement as a tool to reduce the tax risk associated with transfer pricing. Companies also face uncertainty about how ongoing global tax reforms will affect them in the coming period.