Do the new TP rules affect my business? | KPMG | RU
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Do the new TP rules affect my business?

Do the new TP rules affect my business?

Russia’s new Transfer Pricing (TP) rules went into force 1 January 2012.

Russia’s new Transfer Pricing (TP) rules went into force 1 January 2012.

When forming and substantiating intra-group prices, our KPMG professionals apply a comprehensive approach to transfer pricing issues. We consider the provisions of effective Russian tax legislation, planned amendments, actual law enforcement practice and principles of international transfer pricing. In this way we help our clients attain their goals.

Transfer pricing could apply to you if you have any cross-border transactions between related parties and one of them is resident in the Russian Federation. Transactions by Russian companies that involve commodities quoted on exchanges, and transactions with legal entities residing in “black-listed” offshore jurisdictions, are also subject to TP audit.

The tax authorities can also audit domestic Russian transactions between related parties.
Whether or not these transactions are subject to TP audit depends on the application of various thresholds and exemptions. As such, the applicability of TP rules must be determined on a case-by-case basis.

What should a company with controlled transactions do to comply?
Companies with controlled transactions must:

  • Notify the Russian tax authorities of controlled transactions by 20 May of the year after the year when the transactions occurred;
  • Provide TP documentation (based on the new requirements) within 30 days after receipt of a request by the tax authorities. TP documentation cannot be requested by the tax authorities earlier than 1 June of the year after the year when the transactions occurred.

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