Instruments of minimization of the risks connected with application of transfer pricing rules

The authors consider the different approaches of minimization of the tax risks connected with application of new transfer pricing regulations - the independent assessment concerning a subject of the transaction, conclusion of the advance pricing agreement and creation of the consolidated group of taxpayers. Advantages and disadvantages of each of instruments are marked out. It is concluded that creation of the consolidated group of taxpayers is the most effective approach for decreasing of transfer pricing risks.