Ardashev A. —
Tax regulation of multinational corporations: development trends in the Russian Federation
// Taxes and Taxation. – 2021. – ¹ 4.
– P. 1 - 8.
DOI: 10.7256/2454-065X.2021.4.31013
URL: https://en.e-notabene.ru/ttmag/article_31013.html
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Abstract: The question of tax regulation of multinational corporations is quite topical. This article analyzes some aspects of tax regulation of multinational corporations in Russia, as well as outlines promising vectors of the development of tax regulation of multinational corporations, taking into account the practice and results of the analysis of information sources suggested for using within the framework of the method of comparable market prices, and correlation between the account statements indicators of independent Russian trade companies. Substantiation is given to the accounting for certain types of other income and expenditures, as well as the need for the implementation of “safe harbor” for transactions with intangible assets. The author offers an alternative for calculating the boundaries of “safe harbor”. In the course of writing this article, the author observed the practice of enforcement of rules that regulate the formation of taxation bases, carried out statistical analysis, and used general logical methods. The conclusion is made that the development of regulation of multinational corporations is a promising direction, as these economic entities generate significant financial flows. The variety of operational models and organization techniques complicate the development of the universal global approach, which consists in distribution of financial results between the accepting countries. Elimination of ambiguity in tax relations is an important vector of development. The article offers the solutions to this problem.
Ardashev A. —
Transfer Pricing: Peculiarities of Taxable Base Development in Intangible Assets Dealings
// Taxes and Taxation. – 2019. – ¹ 4.
– P. 1 - 10.
DOI: 10.7256/2454-065X.2019.4.29666
URL: https://en.e-notabene.ru/ttmag/article_29666.html
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Abstract: The subject of the research is the development of taxable bases as part of dealings concluded with subsidiary economic entities of trans-national companies about intangible assets. The aim of the research is to develop recommendations on how to manage the development of taxable bases in intangible assets dealings concluded by trans-national companies in order to prevent international profit shifting and base erosion as well as to solve an important economic task of preservation of Russia's taxable base under the conditions of international tax competition. Within the framework of the research, Ardashev has applied the method of observation over practical implementation of rules that regulate taxable base development. He has also compared particular aspects of national rules with their foreign compatibles and has used other general-logic methods. Ardashev has also carried out empirical research of data collected from public sources. The novelty of the research is caused by the fact that the author raises the problem of regulating taxable base development in the structures of trans-national companies. He offers recommendations on how to choose formal and essential approaches to such regulation. This has been done based on the example of intangible assets dealings because these are the most difficult dealings when it comes to pricing based on the arm's length principle. The researcher also describes grounds for the distribution of the legislative pricing practice and creation of 'safe harbors' to non-intangible assets dealings concluded by trans-national companies.