Mikhail Golovanev, Tax Litigation Project Manager at FBK Legal, has participated in the conference titled “Tax Results of the Year” held by the Vedomosti business daily.
He spoke about price control for taxation purposes at the session dedicated to tax risk management and business optimisation strategies. He said that the procedure for transaction price control has been finalised this year and no significant changes are expected over the coming years.
“At the same time we need to pay attention to practices applied by regional tax authorities in detecting price manipulation in transactions that are not classified as controlled. Here we should note an important result of the year 2018. More and more often courts rule that it is unlawful for tax authorities not to follow the methodology of the specific price control technique stipulated in Section V.1 of the Russian Tax Code. The legal rationale here is that if one price control technique is applied to charge additional taxes, it is strictly obligatory to follow its methodology. This approach is really important to stabilize court rulings in such type of cases.
“Tax Results of the Year” is a business event held to discuss relevant and significant tax issues and socialize about the results of the discussion. It is attended by government officials, finance directors, heads of tax planning and administration departments, heads of tax management departments, chief accountants, heads of companies, and heads of tax practice at law, auditing and consulting companies