Template-Type: ReDIF-Article 1.0
Author-Name: Andrey S. Kizimov
Author-Email: finjournal@gmail.com
Author-Workplace-Name: Ministry of Finance of the Russian Federation
Author-Name: Nadezhda A. Kuzmina
Author-Email: finjournal@gmail.com
Author-Workplace-Name: Ministry of Finance of the Russian Federation
Author-Name: Milyausha R. Pinskaya
Author-Email: Mpinskaya@fa.ru
Author-Workplace-Name: Financial Research Institute, Russia; Financial University under the Government of the Russia
Title: Tax Control of Transfer Pricing on Intangible Assets
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.
Classification-JEL: H26, H87, F37
Keywords: transfer pricing, affiliated persons, intangible assets, comparability of transaction, tax control
Journal: Finansovyj žhurnal — Financial Journal
Pages: 7-15
Issue: 3
Year: 2016
Month: June
File-URL: http://www.nifi.ru/images/FILES/Journal/Archive/2016/3/statyi_3/01.pdf
File-Format: Application/pdf
Handle: RePEc:fru:finjrn:160301:p:7-15