International Assembly of Tax Advisers in St-Petersburg
Date of publication
23.09.2013The central purpose for the participants in the event – the leading experts in the field of taxation from Russia, the CIS countries, Europe and Asian-Pacific region – was to discuss the attitude of the professional community to the international taxation.
Alexei Yakovlev, FBK Legal, Head of Tax Litigation Practice, represented FBK Legal at the forum. He took part in the session on discussing “Transfer pricing: practical questions”.
In his report “Practical aspects of application of the RF TC methods to determine the correspondence of price in the deal and the market price” A. Yakovlev described the principles of selecting this or that legally provided method of transfer pricing as well as the consequences of such selection and the key problems arising at the procedure.
20 November 2013 is the deadline for submitting information about the controlled deals and many major taxpayers are doing the required work, so the participants in the discussion met the report with interest.
In the course of the session the experts also discussed:
- Practical aspects of applying the transfer pricing rules to the intra-group management agreements and cost-sharing agreements;
- Using information for the purpose of substantiating the prices in the controlled deals;
- Functional analysis; the contents and scope;
- Transfer pricing in relation to intangible assets,
In the session of discussions on the “Transfer pricing: practical questions” along with Alexei Yakovlev also took part:
- A.L. Overchuk, deputy head of the Federal Tax Service of Russia;
- D.V. Volvach, head of the Department for Transfer Pricing and International Cooperation, the FTS of Russia;
- The leading specialists in transfer pricing representing the largest Russian and international consulting companies.
Steven Colclave, CIOT President (Great Britain), acted as the moderator at the session.