Tax Control of Transfer Pricing on Intangible Assets

Andrey S. Kizimov (), Nadezhda A. Kuzmina () and Milyausha R. Pinskaya ()
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Andrey S. Kizimov: Ministry of Finance of the Russian Federation
Nadezhda A. Kuzmina: Ministry of Finance of the Russian Federation
Milyausha R. Pinskaya: Financial Research Institute, Russia; Financial University under the Government of the Russia

Finansovyj žhurnal — Financial Journal, 2016, issue 3, 7-15

Abstract: The article is focused on methodology of tax control on transfer pricing in respect of transactions involving intangible assets. Authors analyzed Russian legislation and court cases and revealed the sources of tax risks of taxpayers and government. These risks are related to the nature of intangible assets (uniqueness, lack of interchangeability), as well as to the differences in interpreting of intangible assets in different sources of legislation. The authors made an analysis of comparability of transactions with intangibles comparing Russian tax legislation and OECD recommendations.

Keywords: transfer pricing; affiliated persons; intangible assets; comparability of transaction; tax control (search for similar items in EconPapers)
JEL-codes: F37 H26 H87 (search for similar items in EconPapers)
Date: 2016
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Persistent link: https://EconPapers.repec.org/RePEc:fru:finjrn:160301:p:7-15

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