Abstract
Development of foreign language professional competence of university instructors requires use of approaches different from those traditionally applied when teaching younger students. Research was conducted to determine the combination of approaches that will be suitable to train university instructors. In the course of the research, teaching approaches used in various countries were compared in terms of their efficiency when applied to adult audience. Moreover, such factors as teaching educators, the roles of a trainer and a learner, increasingly international environment and the learning environment were considered. Finally, implications of using teaching approaches when training educators were analyzed and the ones with the highers potential to produce the desired outcomes were selected. As a result the authors suggest that androgogical, competence-based, environmental, dialogic and student-centered approaches should be used to maximize learning outcomes in adult learners.
Highlights
In the process of tax control of transactions between interdependent persons, the tax authorities use methods that justify and confirm the fact that the prices applied in transactions between interdependent persons are market-based
The tax control methods for transactions between interdependent persons regulated by the Tax Code of the Russian Federation are based on international rules for the regulation of transfer pricing laid down according to the recommendations of the Organization for Economic Cooperation and Development (OECD)
- The tax authority must justify and prove the impossibility of applying the previous transfer pricing method before proceeding to the analysis of the current transfer pricing method used in the transaction (Baburyan, 2014)
Summary
In the process of tax control of transactions between interdependent persons, the tax authorities use methods that justify and confirm the fact that the prices applied in transactions between interdependent persons are market-based. The tax control methods for transactions between interdependent persons regulated by the Tax Code of the Russian Federation are based on international rules for the regulation of transfer pricing laid down according to the recommendations of the Organization for Economic Cooperation and Development (OECD). - The choice by the taxpayer of an optimal pricing method which, taking into account all aspects of the analyzed transaction, will give the most accurate and well-reasoned conclusion about the conformity of the price applied in the analyzed transaction to the market level;. - A comprehensive analysis of the parties to the transaction, taking into account the available data, including the rationale for choosing the pricing method, the criteria for comparability and interdependence, etc.;. - The tax authority must justify and prove the impossibility of applying the previous transfer pricing method before proceeding to the analysis of the current transfer pricing method used in the transaction (Baburyan, 2014)
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