English to Russian Other Law: Taxation & Customs

Where the arrangements made in relation to a transaction between connected persons, viewed in their totality, differ from those which would have been adopted by independent persons behaving in a commercially rational manner in comparable circumstances, thereby preventing determination of a price that would be acceptable to both of the parties taking into account their respective perspectives and the options realistically available to each of them at the time of entering into the transaction the actual transaction as structured by the taxpayer may be disregarded for the purposes of these rules, in which case the arm’s length position would be as if the transaction had not occurred. In other cases, if appropriate, the transaction should be replaced by an alternative transaction.