Approach to reporting on transfer pricing in the CIS countries

Abstract

The article examines the main obligations of taxpayers in various CIS countries and their differences in comparison with the approach adopted by the OECD countries, in particular, the widespread obligation to file notifications of controlled transactions, the specifics of the requirements for filing three-level reporting, etc. The object of the study is the provisions of the legislation of the analyzed countries in the field of transfer pricing, by-laws and regulations issued by individual public authorities, and the subject of the study is the main regularities of regulation, as well as differences in the requirements for the preparation and submission of reports on transfer pricing. The main conclusions of the study are the high degree of specificity of taxpayers' obligations in the field of transfer pricing in the CIS countries, as well as the general unity of approach among the analyzed countries. As part of the work, it was also found that, taking into account the trends towards convergence of legal norms among the CIS countries, there is a high probability of further increase in the administrative burden on taxpayers, in particular, the adoption of TP rules by those countries that have not yet adopted them, and the introduction of three-level reporting in those countries in which such a requirement is not yet available. The novelty of the research lies in the formation of an up-to-date comparative characteristic of legislative norms, as well as the identification of possible trends in the development of legislation based on the history of the development of TP rules in the CIS countries.