Controlled Transactions: Features of Legal Regulation of Tax Control

The article provides a theoretical analysis of the regulatory legal regulation of foreign trade controlled transactions in order to further improve legal regulation. It is noted that in the case of controlled transactions, tax control over prices applied in such transactions is carried out by a special structural unit of the Federal Tax Service. The subject of on-site and desk inspections cannot be price control in such transactions. It is noted that since January 1, 2024, there have been significant changes in the composition of the information provided in the notification and documentation provided by the taxpayer. In particular, starting in 2024, it will be necessary to provide information on the assets used related to the transaction under review, as well as on the economic risks assumed. This information must be confirmed by the relevant documents provided to the tax authorities. From 2024, documentation on verifiable transactions can be requested outside the framework of the Abm.