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

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, KPMG professionals apply a comprehensive approach on transfer pricing issues, considering the provisions of effective Russian tax legislation, planned amendments, law enforcement practice and international transfer pricing principles. In this way we can help clients attain their goals.

Yes, if you have any cross-border transactions between related parties and one of them is a Russian resident (is registered in the Russian Federation). Russian companies’ transactions involving commodities quoted on exchanges and transactions with legal entities residing in “black-listed” offshore jurisdictions are also subject to TP audits.

In addition, the tax authorities can audit domestic Russian transactions between related parties.
Whether or not these transactions are subject to TP audit depends on various thresholds and exemptions. Therefore, the applicability of the TP rules must be determined case-by-case.

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 a request by the tax authorities. The TP documentation may be requested by the tax authorities not earlier than 1 June of the year after the year when the transactions occurred.

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