Taxation of income from transactions between related perties: development of legislation and unresolved issues

The article discusses the formation of the legislation of the Russian Federation, which regulates the taxation of income in transactions between interdependent persons through the prism of evaluating the effectiveness of regulatory transformations. Positive aspects are noted related to the specification of criteria for recognizing individuals as interdependent, the regulation of tax audit methods for these individuals, issues of combating abuse of rights, and the introduction of the institution of international groups of companies, the analysis of tax legislation and law enforcement practices is carried out taking into account domestic and international experience. In addition, within the framework of the study, shortcomings arising from legislative constructions in regulating issues of taxation of income from transactions between related parties are identified, suggestions are made for their optimization. As a result of the analysis of the legislative regulation of taxation of interdependent persons by the author, in order to increase the efficiency of the tax system, a conclusion is drawn about the need for expanded refinement of the rules for symmetrical adjustments and taxation in foreign trade operations.