TRANSFER PRICING AS A WAY OF MINIMIZING THE TAX BURDEN: INTERNATIONAL EXPERIENCE OF COUNTERACTION

摘要

The article analyzes transfer pricing used by a number of TNCs and MNCs as a way of minimizing the tax burden, which is often accompanied by significant social losses, especially sensitive for developing countries. In this context, the article focuses on the following issues: 1) historical aspects of development of transfer pricing; 2) economic evaluation of losses incurred by transfer pricing and a number of other methods of tax optimization; 3) new trends in the application of transfer prices in the conditions of digitalization of the world economy; 4) the logic of the development of international legislation in the field of transfer pricing. The article concludes with an analysis of a new order of normative regulation, called "BEPS" Action Plan, which is aimed primarily at solving the problems in the field of taxation of the digital economy which is also of great importance for Russia.