Abstract

In the first part of the publication the author characterizes the principle of the specificity of legal provisions, so that in the second part she can submit to analysis current and in progress provisions regarding transfer prices. The author especially calls attention to a vague concept of “transaction”, also within the project. Moreover, apart from analysis of completing test of specificity of legal provisions, the author calls attention to other planned changes, e.g. within the scope of methods of setting transfer prices, concept of “related parties”, or in the scope of revision after control or comparative analysis.

The subject of the publication is anindication ofsome of interpretative doubts connected with transfer prices which may result from vagueness of these legal provisions, therefore they can currently and in the future cause difficulties for taxpayers in mandatory completion of documents regarding transactions with related parties. Moreover, they can prompt a significant risk with authorities which control transfer prices. Meeting demands of a test of specificity of legal provisions should be analyzed in detail on the stage of creating provisions if the changes aim to clear doubts away, otherwise it will be necessary to issuefurther explanations or interpretations.