One of the most discussed topics throughout 2018 was active implementation of a risk-based approach among tax authorities. This article covers the highlights of 2018 associated with the advent of the "digital era" of taxation.
Olga Kuramshina

Olga Kuramshina
Ex-Leading Lawyer
Tax and Legal Practice
Korpus Prava (Russia)
The Organization for Economic Co-operation and Development, or the OECD approved a global response plan with the Base Erosion and Profit Shifting, or the BEPS in 2013

Syndicated credit (loan) is a financial instrument, which provides for getting loan-based funding from several persons and sharing rights, obligations and risks attributable to lending among them.

In 2015 and 2016, several cases based on pricing regulation norms were already heard by arbitration courts, however, they mainly covered either rights of local tax authorities to apply provisions of transfer legislation when proving unjustified tax advantages, or conditions of qualifying parties as interdependent.