LA DETERMINATION DES PRIX DE TRANSFERT A LA FRONTIERE ENTRE BONNE GOUVERNANCE ET EVASION FISCALE

Résumé

This article attempts to bring a different vision to the problem of determining transfer prices in multinational groups by clarifying that this question is part of the management tools before constituting a stratagem aiming to relocate a profit, geographically, for tax optimization and, often also, tax evasion. Its content is oriented, mainly; to the Moroccan context which is currently undergoing major changes in this complex area of international taxation. Regarding this last point, the article offers some recommendations aimed at enriching our doctrine on the subject.