Transfer pricing

The tax authority's position on the application of price adjustments between parties to a financial and economic transaction has been appealed as part of the tax audit of transfer pricing.

• Employee involved

  Mikhail Begunov

• Process description

  Price adjustment would have entailed an additional charge of income tax on the formed tax base based on the market prices of the transaction. The project developed a legal position indicating that the formed pricing corresponds to the market level, because the calculation of the cost of the taxpayer's goods contains production costs, economically justified in terms of the type of activity.

• Result

  As a result of the successful legal defense, additional tax assessments in the amount of 280 million ₽ were avoided.