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THE SYSTEM OF TRANSFER PRICING
Abstract
The problem of the tax consequences of transfer pricing is now quite urgent for the federal and regional budgets. Transfer pricing is one of the most common ways to minimize taxes. The result of the globalization of the world economy has become the free flow of financial resources, which led to a sharp rise over the past three decades, the number and the economic power of multinational integrated companies. Such structural shifts in the world economy dictate new requirements for the formation of tax systems, and companies to open up opportunities for tax optimization. The structure of the tax systems of most countries based on the taxation of financial results. The value of income affects the size of the tax base for corporate income tax, value added tax, tax on capital gains. In turn, the income generated from the value of the revenue of the company and the amount of expenses incurred. The prices, at which transactions concluded, are a key factor influencing the amount of revenues and expenses. Thus, pricing provides many opportunities for the distribution of profit between affiliated organizations and, of course, this distribution carried out in the manner most favorable to the holding as a whole. For such a pricing system adopted in international practice, introduced the term "transfer pricingВ». The global financial and economic crisis has led to an increase in budget deficits states. In search of more revenue, the government taking steps to seek provisions in the tax administration and the development of method for assessing tax risks. The result of research is the mechanism of the State Administration of transfer prices for tax purposes, which allows controlling prices on emerging now new types of relationships between the units of the corporation.
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