Abstract: The article examines the main obligations of taxpayers in various CIS countries and their differences in comparison with the approach adopted by the OECD countries, in particular, the widespread obligation to file notifications of controlled transactions, the specifics of the requirements for filing three-level reporting, etc. The object of the study is the provisions of the legislation of the analyzed countries in the field of transfer pricing, by-laws and regulations issued by individual public authorities, and the subject of the study is the main regularities of regulation, as well as differences in the requirements for the preparation and submission of reports on transfer pricing. The main conclusions of the study are the high degree of specificity of taxpayers' obligations in the field of transfer pricing in the CIS countries, as well as the general unity of approach among the analyzed countries. As part of the work, it was also found that, taking into account the trends towards convergence of legal norms among the CIS countries, there is a high probability of further increase in the administrative burden on taxpayers, in particular, the adoption of TP rules by those countries that have not yet adopted them, and the introduction of three-level reporting in those countries in which such a requirement is not yet available. The novelty of the research lies in the formation of an up-to-date comparative characteristic of legislative norms, as well as the identification of possible trends in the development of legislation based on the history of the development of TP rules in the CIS countries.

Abstract: The subject of this research is the transfer-pricing rules applied in various countries, their peculiarities and flaws from the standpoint of approach to taxation of transnational corporations overall; as well as practical issues of implementation of transfer-pricing rules for transnational corporations and fiscal authorities, namely the problems of avoidance of taxation by the representatives of transnational corporations and ambiguity of the applied approaches towards regulation. The author examines differences in the rules applied by various jurisdictions, as well as law enforcement problems emerging thereof. Relevance of the topic is substantiated by high significance of transfer-pricing rules for taxation of transnational corporations, as well as the need for ensuring universality in international taxation. The main conclusions lie in determination of substantial ambiguity in the transfer-pricing riles, associated with the lack of information on comparable transaction in the available information systems, as well as assessment of rules with regards to each individual situation. The mechanism employed by the Organization for Economic Cooperation, aimed ate elimination of flaws in transfer-pricing rules, such as consensual procedure, are expensive and often ineffective for transnational corporations. Therefore, elimination of dual taxation is achieved only in some situations. Differences of legislation on transfer pricing in various jurisdictions can also lead to dual taxation of transnational corporations. Moreover, the “arm’s length” principle do not allow reflecting synergetic effects that emerge in the context of activity of transnational corporation, and thus, definition of taxation base within the framework of acting transfer-pricing rules is incomplete.