Author(s): Vladimir S. Belykh, Tatyana V. Stadnik
The article considers some issues of the doctrinal and normative definition of the grounds for recognition of "related parties", as well as scholarly discussion regarding the development of a unified concept for various branches of law. Using the method of analysis and synthesis, the authors emphasize the discrepancy between the lexical meaning of the term "interdependent persons" and its definition in Russian law. They support the opinion of civil law scholars on the need to use a single definition of "related persons" both in tax law and in customs law for price control. They also propose to improve the criteria of dependence with the legally confirmed possibility to dispute them. Their analysis shows that the transfer pricing rules discord with the logic of the activity of integrated industrial complexes. Therefore, the authors state that it is necessary to define indicators of transactions between companies involved in an integrated production cycle within the national jurisdiction, with their subsequent exclusion from the sphere of tax control.