Transfer pricing control in Common Economic Space Member States and its implications

Belarus, Kazakhstan and Russia recently formed Common Economic Space to ensure free movement of goods, services, capital and labour, which attracted a number of multinational companies. CES Member States harmonized some approaches and procedures to make the free movement happen, but there is long way to go ahead. One of the issues to solve is tax control approaches, transfer pricing control being one of its crucial points. In this article the author provides an overview and comparison of the transfer pricing control rules of CES countries and outlines the differences which affect cross-border business. The further discussion considers how exactly these differences create the obstacles for free trade in common market. Three approaches to solve this issue are then suggested: the one based on Simultaneous Tax Examinations, the second one based on mutual agreement, and the third one based on model legislation.