International experience in transfer pricing

Abstract

The article is devoted to topical issues of the development of transfer pricing, which are determined by a number of circumstances. The purpose of the study is to assess the risks of transfer pricing according to international experience. Assessments of transfer pricing risks based on the necessary reliable information, which should be one of the important factors in the development of transfer pricing documentation norms, have been studied. The use of various means in different countries for obtaining information from taxpayers, necessary for effective assessment of transfer pricing risks, is considered. The problems of transfer pricing risks are outlined, which develop and change over time and lead to the emergence of new issues and challenges; the need for significant interaction of taxpayers with tax authorities in the course of working out the risks of transfer pricing, which actually leads to the so-called greater tax certainty in exchange for transparency of activity. Problems in accordance with a clear and well-founded policy of transfer pricing, risks and international experience in transfer pricing issues are revealed, which shows that the processing of transfer pricing risks (their establishment, research, analysis and assessment of the impact on the tax base of the taxpayer) occupies a significant place in the processes of tax control over transfer pricing and pursues two main goals: ensure proper selection of transactions for transfer pricing audit; decide on a list of questions to be worked out during the transfer pricing audit. The importance of documenting the results of risk identification and the process of their assessment for the purpose of making further management decisions and carrying out control, as well as further storage in case of the need to analyze their validity and compliance with the rules of transfer pricing, is characterized. Prospects for further research are given, which consist in the classification of transfer pricing risks, which are useful for providing additional content (context) and opportunities for identifying potential transfer pricing risks and determining the process of their assessment.