World experience of tax control in the field of transfer pricing

Kupriyanov Aleksandr Sergeevich

The article provides a brief analysis of current international principles of tax control in the field of transfer pricing, as well as the state of the legislation of foreign countries in the designated area. The countries are classified in terms of the level of implementation of international transfer pricing rules. Based on a comparative legal analysis of the regulatory sources of foreign countries in the field of taxation of interdependent persons, the most characteristic features and problems are highlighted. As a result of the study, the possibility of introducing positive experience into the domestic tax system is considered, possible directions for improving the institutions of the tax law of the Russian Federation are identified.

Keywords:interdependent persons; tax control; controlled transactions; OECD transfer pricing; preliminary pricing agreement; transnational corporations; the principle of "outstretched arms"