Transfer pricing rules in the consumer co-operative system

The special tax rules on arm"s length transfer pricing, an internationally recognised mechanism regulated by the OECD Transfer Pricing Guidelines for Multinational Enterprises, represent a real challenge for economic agents in the Republic of Moldova. These special rules on transfer pricing apply to both cross-border and local transactions between related persons in order to prevent tax evasion. To ensure compliance with the provisions of the tax legislation in force by consumer co-operative entities in the Republic of Moldova, several issues need to be clarified. It is necessary to determine whether consumer co-operative entities are subjects of these relationships, i.e., affiliated persons whose transactions may harm the public budget. The particularities of the functioning of the consumer co-operative system in the Republic of Moldova raise questions about the status of local transactions carried out between consumer co-operative entities that benefit from different tax regimes. Last but not least, it is important to clarify the particularities of transfer pricing in the case of the provision of services, including financial services.