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Comparative Analysis of Transfer Pricing Legislation in Russia and in the USA

ФИО студента: Anastasiya Yugina

Руководитель: Elena Ryabova

Кампус/факультет: Faculty of Law

Программа: Jurisprudence (Bachelor)

Год защиты: 2018

Transfer pricing is a mechanism of establishing the prices in transactions with related parties and might be used in order to group the profits of an international group of companies in the jurisdictions with a low tax rate. Such an application of transfer pricing contradicts the public interests of the government in each of the countries, in which such a group operates. In Russia the current transfer pricing rules came into force in 2012 as an amendment to the Russian Tax Code. The main purpose of the study is the analysis of legislative norms in Russia and in the USA, as the country which was the first to implement the transfer pricing legislation. The conclusions of the study are based on comparative analysis of the legislation development in Russia and in the USA, and the courts’ positions on the most questionable matters of the application of the transfer pricing rules. The conclusions confirm the overall tendency of convergence in the regulation of transfer pricing, and also identify legislative differences, which might create additional tax risks for the taxpayer.

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