Transfer pricing is young phenomenon for the world of taxes. It arose in the 1960th years thanking active development of economy and development of large corporations. The first document which became a regulator of the transfer pricing was Declaration of the participating countries of the Organization for Economic Cooperation and Development (OECD), accepted in 1976. Subsequently, the countries who was engaged in reforming of the taxation and transfer pricing, adapted the legislation under the features of market characteristics and governmental policy in the field of economy.
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The conducted research represents the comparative analysis of development of transfer pricing in Russia and abroad taking into account economic, political, geographical and social features of the countries. On the basis of the received results, the forecast of possible further ways of development of this branch of the taxation was made.