TAX CONTROL IN TRANSFER PRICING
Ключевые слова:
Tax control, Transfer pricing, Related entities, Tax jurisdiction, Arm's length principle, Tax evasion, Profit reporting, Regulations, Documentation, Enforcement mechanisms.Аннотация
This article explores the concept of tax control in transfer pricing, focusing on the regulation and examination of transactions between related entities across different tax jurisdictions. It discusses the importance of ensuring that these transactions are conducted at arm's length to prevent tax evasion and ensure accurate reporting of profits. The article examines the key components of effective tax control in transfer pricing, including regulations, documentation requirements, and enforcement mechanisms.
Библиографические ссылки
OECD. (2017). Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations. Paris: OECD Publishing.
United Nations. (2013). Practical Manual on Transfer Pricing for Developing Countries. New York: United Nations Publications.
Internal Revenue Service. (2020). Transfer Pricing Audit Techniques Guide. Washington, D.C.: U.S. Department of the Treasury.
International Tax Review. (2020). Transfer Pricing News and Analysis. International Tax Review, 2020(1), 50-65.
Journal of International Taxation. (2019). Title of Article. Journal of International Taxation, 2019(3), 112-125.