THE ESSENCE OF DOUBLE TAXATION IN TRANSFER PRICING

Abstract

The article is devoted to the study of the essence and nature of double taxation in the conditions of transfer pricing. The crux of the problem is that profits from transfer transactions may be subject to taxation in both countries where the related parties are located. This can create complications and misunderstandings between countries, as well as cause conflicts between businesses and tax authorities. The main goal of solving the problem of double taxation in transfer pricing is to create a stable and transparent system that satisfies the interests of all parties. International standards and dispute resolution mechanisms play a key role in achieving this goal, ensuring a fair and clear playing field for all participants. In the further development of transfer pricing and the fight against double taxation, it is important to continue the development and implementation of effective international standards, as well as to strengthen cooperation between countries and enterprises. Only in conditions of mutual understanding and cooperation will it be possible to ensure an effective and fair transfer pricing system that considers the interests of all parties.