TAX COMPLIANCE CONTROL AND AUDIT OF TRANSFER PRICING TRANSACTIONS

Abstract

The article presents the authors' vision of the features and mechanism of tax compliance control and audit in the management of transfer pricing operations. Effective interaction between business entities and tax authorities in the process of controlling and auditing transfer pricing transactions should be based on the principles of compliance with the help of two tools – assessment of the quality of transfer pricing policy and internal control system (as a result of interaction of internal and external control systems) and assessment of the quality and effectiveness of internal audit of transfer pricing (as a result of interaction of internal control and audit systems). In accordance with the above, tax compliance control and audit becomes a new element of the established system of monitoring of controlled transactions of a business entity, which proposed to understand as the use of tools to confirm the quality and effectiveness of internal control and audit systems of transfer pricing transactions of a business entity by a tax authority, which certifies the taxpayer's commitment and responsibility to comply with tax legislation in terms of compliance with the arm's length principle. Confirmation by the tax authorities of the quality of the transfer pricing policy and internal control and audit system of the entity should be based on the developed, tested and approved system of assessment parameters. Confirmation of the assessment of the quality of the transfer pricing policy and internal control system will demonstrate the responsible position of the taxpayer based on tax compliance with the transfer pricing legislation in accordance with the arm's length principle and will increase the level of trust in it on the part of the tax authorities. In turn, the introduction of such a tool as an internal transfer pricing audit quality assessment into the process of monitoring-controlled transactions will allow the company to submit and use the results of its internal audit in assessing transfer pricing risks to form its tax rating and assess the need to include it in the audit plan. This tool assumes that the internal audit system is sufficient to timely detect violations of tax legislation in the field of transfer pricing in accordance with the arm's length principle.