The Resource Russia's outbound transfer pricing litigations : weak CUP versus questionable TNMM

Russia's outbound transfer pricing litigations : weak CUP versus questionable TNMM

Label
Russia's outbound transfer pricing litigations : weak CUP versus questionable TNMM
Title
Russia's outbound transfer pricing litigations : weak CUP versus questionable TNMM
Creator
Subject
Language
eng
Summary
This article addresses three litigations between the Russian Federal Tax Service and Russian producers of certain commodities destined for export via distribution affiliates in low-tax jurisdictions. In each litigation, the issue could be posed as whether the foreign distribution affiliate's gross margin was reasonable. The Federal Tax Service, however, attempted to evaluate the appropriate transfer pricing by an application of the comparable uncontrolled price (CUP) approach, even though its analysis begged the question as to whether the third-party transaction was sufficiently comparable to the controlled transaction to be applied without adjustments for potential comparability differences
Citation source
In: Journal of international taxation. - New York. - Vol. 30 (2019), no. 6 ; p. 49-55, 64
http://library.link/vocab/creatorName
McClure, J.H
Geographic coverage
  • Asia
  • Europe
Language note
English
http://library.link/vocab/subjectName
  • transfer pricing
  • CUP method
  • TNMM
  • case law
Label
Russia's outbound transfer pricing litigations : weak CUP versus questionable TNMM
Instantiates
Publication
Label
Russia's outbound transfer pricing litigations : weak CUP versus questionable TNMM
Publication

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