Generolo Jono Žemaičio Lietuvos karo akademija

International fiscal regulation of transfer pricing solves important taxation problems of company groups to ensure fair distribution of the taxation base between different jurisdictions and in one country. The alternative to the arm’s length principle for similar problems is a concept of formulary apportionment approach. The need to solve such problems is pressing for the Russian consolidated tax groups too, primarily in the technology and capital-intensive industries. Russian Federation’s seven-year experience of creating the consolidated tax groups based on the formulary apportionment approach can be of interest to the specialists in any country researching such issues, because the government has acknowledged the current Russian system ineffective. Economic approach to formation of a sectorial cashgenerating unit grouped according to economically integrated businesses and an investor control concept over an investment facility is the basis of our research. Practical calculations were done for the current consolidated tax group, confirming the advantages of this approach for fair distribution of the taxation base for the technology and capital-intensive industries. We have drawn executives’ attention to the solutions enhancing investment attractiveness of the tax groups in conditions of restricted access to information for external users in the IFRS reports of a group.