Risk management in transfer pricing

Abstract

The article deals with the implementation processes of Base Erosion and Profit Shifting Plan
(BEPS Plan) in taxation systems of different countries. It is outlined that the “substance over form” conception allowing counteract transaction risk manipulation is stated in the new OECD Manual
version. New rules of price determination in controlled transactions based on risk management are
represented. Statistic data on foreign direct investment in the Russian economy and consequences
of affiliation of Russia with the Agreement of automatic exchange of financial and tax information
are analyzed.