Peculiarities of Transfer Pricing Supervision in Uncontrolled Transactions
The aim of this article is to scrutinize the authority of tax agencies concerning the transfer pricing supervision in uncontrolled transactions among related parties. The interpretation of tax laws by the Russian Federal Tax Service has significantly broadened the supervision capabilities of tax age...
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| Format: | Article |
| Language: | English |
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North-West Institute of Management, Branch of Russian Presidential Academy of National Economy and Public Administration (RANEPA)
2025-01-01
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| Series: | Теоретическая и прикладная юриспруденция |
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| Online Access: | https://www.taljournal.ru/jour/article/view/481 |
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| _version_ | 1841536693110308864 |
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| author | E. Sh. Saliakhutdinov |
| author_facet | E. Sh. Saliakhutdinov |
| author_sort | E. Sh. Saliakhutdinov |
| collection | DOAJ |
| description | The aim of this article is to scrutinize the authority of tax agencies concerning the transfer pricing supervision in uncontrolled transactions among related parties. The interpretation of tax laws by the Russian Federal Tax Service has significantly broadened the supervision capabilities of tax agencies over taxpayer transactions initially not meant for scrutiny, resulting in ambiguity and inconsistency in legal proceedings. The article provides an analysis of the legal framework, methodology, and procedures for tax control of prices in uncontrolled transactions, as well as examines the concept of “multiple price deviations” and taxpayer defense strategies. The methodological basis of the article includes both general scientific and specialized scientific methods. In particular, the author employs analysis, synthesis, formal legal, and historical-legal methods. The findings suggest disparities in the treatment of taxpayers in transfer pricing supervision due to the absence of specific safeguards outlined in Section V.1 of the Tax Code of the Russian Federation. Consequently, the author advocates for an extension of transfer pricing laws to encompass all taxpayers, thereby ensuring parity in rights and protections while mitigating arbitrary actions and uncertainties by tax agencies, thereby fostering a more equitable and transparent tax supervision system. |
| format | Article |
| id | doaj-art-502668d4a5d74da9b2ee5d30b4627bda |
| institution | Kabale University |
| issn | 3034-2813 |
| language | English |
| publishDate | 2025-01-01 |
| publisher | North-West Institute of Management, Branch of Russian Presidential Academy of National Economy and Public Administration (RANEPA) |
| record_format | Article |
| series | Теоретическая и прикладная юриспруденция |
| spelling | doaj-art-502668d4a5d74da9b2ee5d30b4627bda2025-01-14T11:56:24ZengNorth-West Institute of Management, Branch of Russian Presidential Academy of National Economy and Public Administration (RANEPA)Теоретическая и прикладная юриспруденция3034-28132025-01-010414014710.22394/3034-2813-2024-4-140-147262Peculiarities of Transfer Pricing Supervision in Uncontrolled TransactionsE. Sh. Saliakhutdinov0BST Consulting, LLC; National Research University Higher School of EconomicsThe aim of this article is to scrutinize the authority of tax agencies concerning the transfer pricing supervision in uncontrolled transactions among related parties. The interpretation of tax laws by the Russian Federal Tax Service has significantly broadened the supervision capabilities of tax agencies over taxpayer transactions initially not meant for scrutiny, resulting in ambiguity and inconsistency in legal proceedings. The article provides an analysis of the legal framework, methodology, and procedures for tax control of prices in uncontrolled transactions, as well as examines the concept of “multiple price deviations” and taxpayer defense strategies. The methodological basis of the article includes both general scientific and specialized scientific methods. In particular, the author employs analysis, synthesis, formal legal, and historical-legal methods. The findings suggest disparities in the treatment of taxpayers in transfer pricing supervision due to the absence of specific safeguards outlined in Section V.1 of the Tax Code of the Russian Federation. Consequently, the author advocates for an extension of transfer pricing laws to encompass all taxpayers, thereby ensuring parity in rights and protections while mitigating arbitrary actions and uncertainties by tax agencies, thereby fostering a more equitable and transparent tax supervision system.https://www.taljournal.ru/jour/article/view/481transfer pricingrelated partiescontrolled transactionsunjustified tax benefitarm’s length principle |
| spellingShingle | E. Sh. Saliakhutdinov Peculiarities of Transfer Pricing Supervision in Uncontrolled Transactions Теоретическая и прикладная юриспруденция transfer pricing related parties controlled transactions unjustified tax benefit arm’s length principle |
| title | Peculiarities of Transfer Pricing Supervision in Uncontrolled Transactions |
| title_full | Peculiarities of Transfer Pricing Supervision in Uncontrolled Transactions |
| title_fullStr | Peculiarities of Transfer Pricing Supervision in Uncontrolled Transactions |
| title_full_unstemmed | Peculiarities of Transfer Pricing Supervision in Uncontrolled Transactions |
| title_short | Peculiarities of Transfer Pricing Supervision in Uncontrolled Transactions |
| title_sort | peculiarities of transfer pricing supervision in uncontrolled transactions |
| topic | transfer pricing related parties controlled transactions unjustified tax benefit arm’s length principle |
| url | https://www.taljournal.ru/jour/article/view/481 |
| work_keys_str_mv | AT eshsaliakhutdinov peculiaritiesoftransferpricingsupervisioninuncontrolledtransactions |