Abstract
The article discusses the crucial role of transfer pricing documentation in the operations and taxation of entitiesengaged in transactions with related parties. It includes an analysis of the guarantee function of transfer pricingdocumentation, which involves providing tax authorities with information to assess the market nature of transactionsand protect taxpayers from challenging the terms of these transactions. The mechanisms of this documentation,its practical application, and the benefits it brings to taxpayers are also discussed. The article presentsexamples from the case law of administrative courts and analyzes the regulations on transfer pricing in corporateincome tax.
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