JUDICIAL AND ARBITRATION PRACTICES NEWS REGARDING TAX CONTROL IN THE FIELD OF TRANSFER PRICING

The relevance of the article is due to the fact that after financial crises, which were exposed to most of the wealthy countries of the world, the level of state control of transfer pricing has increased. But, since this sphere is relatively new for the Russian Federation, which is manifested both in the absence of systemic legislative regulation and systematic theoretical developments in this field, there is an urgent need to study the validity and legal regulation of state control in the sphere of transfer pricing in general. Materials and methods. The theoretical basis of the articles were the works of Vasilyeva M.V., Tchaikovsky V.A., Golishevsky V.I. and other Russian and foreign researchers. The regulatory framework of the study was the Tax Code of the Russian Federation, other legislative acts of the Russian Federation and a review of arbitration practice in the field of transfer pricing. The methodological basis of the study was the systemic method, thanks to which theoretical information was analyzed regarding the features of transfer pricing. The analysis and synthesis method, as well as the comparative method, were used to study the practice of arbitration disputes in the field of transfer pricing. Results. The main aspects of the peculiarities of the tax legislation of the Russian Federation are considered, and the large role of judicial arbitration practice in relation to tax control in the field of transfer pricing is revealed. The article discusses several practical cases of judicial decisions that actually play the role of precedents in the Russian legal field. Conclusion. The topic of transfer pricing is especially relevant in the Russian Federation today, since there is no systematic and complete legislative regulation of this area. Extensive litigation and arbitration practice has actually become the case law in this area. It is worth noting that a large number of disputes end in favor of the tax authorities, which often looks unreasonable. It is worth noting that today the Russian Federation does not have a structure for studying a transaction by tax authorities to comprehensively study the process of pricing to assess its correctness.

transfer pricing, tax control, arbitration practice, transfer pricing and taxes, tax control of transfer pricing