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This article studies the main provisions and features of transfer pricing regulation in the Russian and international tax practice. In the context of the transition to the digital economy, the current transfer pricing methods fail to match modern business models in terms of approaches to value creation. Thus, it is necessary to examine the main aspects of developing the state regulation of transfer pricing in the Russian Federation to determine the main shortcomings of the Russian price control in controlled transactions. The article presents the typical features of controlled transactions and the prospective use of blockchain technology in the management of transfer pricing.

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