Analysis of the application of tax control over transfer pricing

Abstract

This article discusses the issue related to the application of tax control in the field of transfer pricing. The author considered the key provisions related to the concept of transfer pricing, the history of the emergence of this phenomenon and its application at present in Russia. An important place in this article is occupied by the analysis of the activities of multinational corporations. The author described the mechanism of corporate governance of a multinational corporation, described the main subtleties related to both direct management and taxation issues. The author justified the importance of considering multinational corporations as one of the most important categories of taxation. In addition, this paper examines the main provisions issued with the assistance of the Organization for Economic Cooperation and Development, examines the specifics of the application of these provisions in several aspects, among which corporate governance and transfer pricing are highlighted. The author was upset by different groups of risks that may arise in the context of the transfer pricing process. In addition, this article highlights the features of the application of the Guidelines of the Organization for Economic Cooperation and Development in Russia. Based on this, a comparative analysis was carried out between those provisions that are used in Russia without any changes, and those that were changed in specific conditions. In the final part of the work, the author described the mechanism of interaction between the transfer pricing process and the existing principles of the Organization for Economic Cooperation and Development, and also considered the existing difficulties that hinder the improvement of the existing system.