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BEPS Plan: new rules of transfer pricing administration

Author

Listed:
  • Nadezhda Mixajlovna Yarceva

    (Russian Foreign Trade Academy, Moscow, Russia)

  • Evgeny Vladimirovich Gorovoy

    (Russian Foreign Trade Academy, Moscow, Russia)

Abstract

The article deals with the basic provisions of Base Erosion and Profit Shifting Plan (BEPS Plan) and examines what ramifications its implementation will have. The provisions of the Final Report on BEPS Actions 8-10, which deal with transfer pricing issues, are thoroughly analyzed. It is pointed out that the most important revisions of the OECD Transfer Pricing Guidelines (2010)refer to the application of the arm’s length principle, transactions with intangible assets and commodities, transfer pricing rules for intra-group service arrangements and transactional profit split method. The article presents a classification of intra-group services for tax control purposes.

Suggested Citation

  • Nadezhda Mixajlovna Yarceva & Evgeny Vladimirovich Gorovoy, 2016. "BEPS Plan: new rules of transfer pricing administration," Russian Foreign Economic Journal, Russian Foreign Trade Academy Ministry of economic development of the Russian Federation, issue 10, pages 93-103, October.
    • Handle: RePEc:alq:rufejo:rfej_2016_10_93-103
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