Abstract
This article deals with the problems of development and promotion of territorial brands on the level of countries, provinces and cities. Such states as Australia and Germany, the Austrian Tyrol and the city of China Hong Kong are the examples of territorial brands, showing their strengths and opportunities for the "advancement" of respective territorial entities. The article presents the author’s formulation of the category "territorial brand". Much attention is paid to the identification of modern world tendencies of development of regional branding. The author has tried to systematize and to analyse each of these trends. It is noted that the creation of territorial brands is an on-going process, the role and importance of which have steadily increased in recent years.
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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