Abstract: Purpose – The purpose of this article is identification and description of risks, which constitute an inherent element of the tax documentation.
Design/Methodology/approach – This article includes monographic research methodology using information in qualitative and descriptive form. Analysis and logical structure method has been applied to the literature on the subject taking into account existing scope of the tax law. The practical part of this article includes case study.
Findings – The research result is quantification of tax risks resulting from cooperation of related companies in the aspect of the transfer prices documentation.
Originality/value – One of the elements of widely understood economic environment is the fiscal environment. The tax law which mainly serve to fiscal purposes, performs one of the basic tax system functions to which the fiscal function belongs. However, the tax law gives companies the opportunity to choose, for example, the form of cooperation especially between companies with capital, organizational and personal links. Business links significantly influence the opportunities of cooperation and at the same time they are a source of the tax risk. Identification and description of the tax risk in the aspect of reliability of the transfer prices documentation seems to be an important problem.