Scientific paper ID 2771 : 2026/1

In the context of the European Council`s proposal for a directive on transfer pricing, this concept covers the determination of prices in transactions between related enterprises belonging to the same multinational group (a so-called multinational enterprise), such as transfers of goods, services, intangible assets, financial capital, etc. These transactions often do not reflect market economic reality, as they are guided by the interests of the group of enterprises. This article examines the main problems faced by both enterprises and tax administrations in the various Member States. It also reviews the proposed solutions aimed at adopting this directive, which is of great importance for the business interests of related enterprises operating in the single European market and, at the same time, for protecting the fiscal interests of European society and citizens.