Legal Framework for Transfer Pricing in Russian Tax Law

The finding of the present study suggest that there is a need of the analysis and formulation of approach to definition of a position of institute of tax control transfer in the tax system of the Russian Federation. For achievement of the specified purpose this article reflects results of the analysis of development of institute of tax control of transfer pricing which is reflected in world practice and in Russia. The results of the present study also suggest the possibilities of using the established international practice of tax control of transfer pricing, reflected in the OECD Guidelines. This study indicates some problems of embedding of institute of tax control of transfer pricing in the tax system of the Russian Federation, its interaction with institutes of tax control, tax responsibility, tax accounting and the reporting, civil institute of the transaction and norms of other industries of the Russian legislation and develops offers on results of the carried-out analysis. The theoretical and practical significance of the work consists in the fact that the study focused on the foundations for the system analysis and interpretation of the rules on tax control of transfer pricing, which will help to orient in a complex set of the considered rules, critically evaluate the positions formed by judicial and administrative practice. The contribution of this study is obvious as the resulting outcomes can be capitalized as guidelines to the norm setting, practical law-enforcement activities and also in practical theoretical significance.