Some problems of transfer pricing and thin capitalization to transactions on loans in Russia

The author considers the problem of discrepancy between the transfer pricing rules and thin capitalization regulation in Russia. Analyzes the relevant provisions of the Tax Code of the Russian Federation (the Tax Code) and international agreements, which resulted in them reveals the essential terminology and contradictions. Believes that the solution is to make the Tax Code in principle amendment. Provides advice on the behavior of taxpayers in the absence of relevant legislative initiatives.