Transfer Pricing | Energy and Resources | 5th edition
We are pleased to announce that International Tax Review, a leading industry publication and the principle source of information for tax specialists across the field, has published the fifth edition of the Transfer Pricing Guide for Energy & Resources sector in collaboration with Deloitte. The volume contains an article by experts from Deloitte CIS, Russia’s application of the Comparable Uncontrolled Price (CUP) Method.
The article was written by Dmitry Kulakov, Alexey Sobchuk, Dmitry Masharov and Anastasia Kopysova, all from the Deloitte CIS Tax & Legal Department.
In the article, our experts discussed three disputes over the application of the CUP method between Russian taxpayers and the Russian Federal Tax Service (FTS). The article considers the specifics of the FTS’s approach to transfer pricing inspections, as well as the main issues that taxpayers should pay attention to when analysing controlled transactions using the CUP method.