摘要：This paper presents transfer pricing and elements of drafting the transfer pricing file by the big companies. The transfer pricing procedure was founded based upon Order no. 442/2016 and the Fiscal Procedure Code and it represents a method upon which the tax base is transferred from a high tax country to a country with low taxation. This legislation outlines the conditions which companies must observe in order to draft the transfer pricing documentation and the significance thresholds. The purpose to draft a transfer pricing file is to reduce the differences between prices and market value and the actual results of company taxation. Economic double taxation occurs when tax authorities apply price adjustments because the company did not respect the principle of market value. Keeping records of transfer pricing and practicing a price aligned to market requirements contribute to an understanding of business development and the creation of appropriate tax planning. Taking into account all these aspects and the fact that any taxpayer is tempted to pay the lowest possible fees,tax havens become an option. In this context we can speak of a tax haven as a loophole in the use of the market price.
