Analiza și verificarea prețurilor de transfer cu ajutorul indicatorului Rata Berry

Abstract

The proposed article explores the interconnections between transfer pricing and the Berry Ratio indicator in the context of profitability verification in business. It analyzes the ways of applying the OECD Guidelines in determining the Berry Ratio, highlighting its sensitivity to the classification of operating costs. Furthermore, the relevance and utilization of the Berry Ratio in the domestic analytical practice are discussed, with a focus on situations where this indicator can provide valuable insights, particularly in intermediary activities. The drawn conclusions underscore the importance of a rigorous approach in using the Berry Ratio and other profitability indicators in transfer pricing verification, emphasizing the need for compliance with international guidelines and the specifics of local tax legislation. CZU: 657.62:338.516; JEL: M41; DOI: https://doi.org/10.53486/issc2024.02