Odpowiedzialność karna skarbowa z tytułu nieprawidłowości w obszarze cen transferowych

Abstract

The aim of the article is to analyze issues related to fiscal penal liability for inspections in the area of transfer pricing in order to obtain an answer to the question regarding the practical documentation of transfer pricing in the context of securing the interests of the State Treasury in the light of criminal fiscal inspections. The first part discusses the basic concepts introducing the subject of transfer pricing and the issue of transfer pricing policy in an enterprise. In the following part, fiscal offenses related to the transfer pricing issue were indicated and discussed, and the rules of incurring fiscal criminal liability in the area of transfer pricing were analyzed. In the conclusions, an assessment of the practical functioning of fiscal criminal liability in the Polish legal order on the basis of transfer pricing was made, making observations regarding its impact on the implementation of the fiscal interests of the State Treasury and the possibility of contributing to the prevention of the economic crisis.