Tax Control System of Transfer Pricing with the Beps Plan

  • Abstract
  • Keywords
  • References
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  • Abstract

    The paper considers the basic principles of the tax control system concerning transfer pricing in foreign and Russian practice. The authors see the main principle of the system in the "arm’s length" concept which allows determination of the validity of the applied price for an intra-company transaction in comparison with its similar conditions and the market price. The authors of the paper suggest an integral system of tax control for transactions between interdependent entities, which includes: the legislatively regulated definition of the market price, the legislatively established regulation of transfer pricing tax control, and the mechanism of penalties for violation of the tax control law for transfer pricing. The latest innovations in the tax control system concerning transfer pricing are based on measures taken by OECD countries to combat the erosion of the tax base (the BEPS plan). The authors of the paper analyze certain provisions of this plan, such as documentation provided by holdings and transnational corporations for the purpose of tax control of transactions between interdependent entities; special attention is also paid to the analysis of tax control over transactions with intangible assets between interdependent entities under the BEPS (Base Erosion and Profit Shifting) plan. Based on the analysis of innovations in accordance with the Base Erosion and Profit Shifting plan, the authors of the article proposed a tax control system for transfer pricing taking into account the latest legislative changes.



  • Keywords

    transfer pricing, tax control, tax base, Base Erosion and Profit Shifting plan, reporting, system.

  • References

      [1] Artemenko D.A. Tax consulting for transfer pricing corporations / D.A. Artemenko, G.A. Artemenko // Scientific Herald of YuIM. - 2015. - No. 3. - p.38-42.

      [2] Sultanova L.F. Realization of the "arm’s length" principle in the transfer pricing / L.F. Sultanova, R.I. Bagautdinov. // Economics and management in the XXI century: development trends. - 2013. - No. 12. - p.146-151.

      [3] N.G. Ivanova. Methodology and practice of tax regulation of transfer pricing / N.G. Ivanova, R.A. Petukhova // Bulletin of the Irkutsk State Economic Academy. - 2015. - No. 3. - P. 464-470.

      [4] A.A. Ponkina. The taxation of transactions between interdependent entities / / The world of modern science. - 2014. - No. 6 (28). - pp.58-61.

      [5] Gorin S.A. Problems of transfer pricing in the context of international tax control // In the collection: Accounting and analytical support - information basis for economic security of economic entities: Interuniversity collection of scientific papers and the results of joint research projects: in 2 parts. - Moscow, 2017. - P. 95-99.

      [6] Yartseva N.M. The Base Erosion and Profit Shifting Plan: New Rules for Transfer Pricing Administration / N.M. Yartseva, E.V. Gorovoy // Russian foreign economic bulletin. - 2016. - No. 10. - p.93-103.

      [7] Evolution of the transfer pricing regulation in Russia: Yesterday, Today, Tomorrow / L.V. Polezharova, A.V. Vinogradova // Economy. Taxes. Law. - 2015. - No. 2. - p. 120-126.

      [8] Shi Y & Eberhart RC, “A modified particle swarm optimizer”, Proceedings of IEEE International Conference on Evolutionary Computation, (1998), pp.69–73.

      [9] Venayagamoorthy GK & Doctor S, “Navigation of mobile sensors using PSO and embedded PSO in a fuzzy logic controller”, Proceedings of the 39th IEEE IAS Annual Meeting on Industry Applications, (2004), pp.1200–1206.

      [10] Parsopoulos KE, Papageorgiou EI, Groumpos PP & Vrahatis MN, “A first study of fuzzy cognitive maps learning using particle swarm optimization”, Proceedings of IEEE Congress on Evolutionary Computation, (2003), pp.1440–1447.




Article ID: 28332
DOI: 10.14419/ijet.v7i4.28.28332

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