أسعار التحويل من منظور القانون الجبائي الجزائري و الاتفاقيات الجبائية الدولية

الملخص EN

A lot of institutions that are connected to the rest of the world and that belong to the same group rely on exchange products and services between each other without involving other institutions that are independent from them.

Search procedure allows is connected companies to evade paying the real value of tax in the country that makes the source of benefits for them.

The transactions that usually happen between such institutions do not represent the real value in most of the times.

In addition the countries that attract such transactions are tax heavens.

The tax administration in Algeria control the transactions between the connected institutions and as a result these administrations seek to fight against the transfer prices by relying on the provisions of tax law as well as the tax treaties made between Algeria and other countries around the world.

The mechanisms adopted in the tax law to curb the phenomenon of indirect transfer of profits do not differ much from those applied in the treaties to prevent double taxation.