Abstract
The goals of Russian Federation state program "The development of fishery complex" # 314 approved by RF Government Decree on April 15, 2014 # 314, include the transition to an innovative type of industrial production the provision of global competitiveness for goods and services produced by the Russian fishery complex. However, a number of problems that exist in the fishing industry of Russian Federation hinder the achievement of the set tasks: the deterioration of the basic production assets, the shortage of efficient cooling capacities for storage, a high level of raw and shadow exports, an unfavorable financial situation for industrial organizations, and an imperfect regulatory and legislative base. These circumstances necessitate the resumption of integration processes, the search for new interaction forms and methods in the fishing industry. The aim of the study, the results of which are reflected in the article, is a quantitative assessment of the factors which contribute to and impede the development of the fishing industry cluster in Primorsky Krai on the basis of the technique application previously developed by the authors. The theoretical basis of the study is the model of M. Porter’s national competitive advantages "rhombus", the critical analysis of which allowed the authors to propose the division of production factors into basic resource and infrastructural ones, which is especially important for the Russian business environment. This transformation served as the basis for the developed methodology, which includes an integral indicator of clustering factor development. The analysis of each of its components on the developed scale allows to identify the degree of cluster initiative implementation, as well as to determine the most effective support measures based on the competitive advantages of the fishing cluster. The determination of the competitive advantages of clusters is carried out by the method of focus group conduct among the experts, and their quantitative assessment is carried out using the questionnaire method, which gives the assessment of the implementation and importance. The developed methodology can be used to develop normative and strategic programs for the creation and the functioning of industrial clusters, the development of which corresponds to the implementation of import substitution processes and the transition of Russia to an innovative type of development.
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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