Transfer pricing services in Russia

All cross-border transactions as well as some local transactions are under strict control of the Russian tax authorities and are subject to Russian transfer pricing rules.  These rules apply to international companies that involved in transactions with Russian subsidiaries/ related parties in Russia and/or Cross-border transactions between unrelated parties involving the sale of certain types of commodities or in case a party to transactions is located in a low-tax jurisdiction (i.e. in a “black-listed” jurisdiction)*

Russian taxpayers involved in cross-border related-party transactions are required to:

1. Notify the tax authorities on cross-border transactions not later than 20 may after the reporting period in the envisaged by the local law;

2. To justify intra-group prices in in the form of transfer pricing documentation (members of multinational groups have to additionally prepare 3-tires transfer pricing reports);

Our team is ready to assist you eliminate transfer pricing risks by providing full support and consultation for any transfer pricing matters.

Our transfer pricing services include:

• Audit of transactions (domestic and cross-border transactions) to identify which of them are subject to transfer pricing control;

• Transfer pricing risk analysis;

• Development and implementation of the efficient transfer pricing strategy;

• development of an internal policy on intragroup pricing in accordance with the Russian transfer pricing rules, OECD recommendations and BEPS action plan 13;

• Development/review & adaptation of transfer pricing documentation and Transfer pricing Notifications, including:

  • Collection and analysis of documents;

  • Determining the most appropriate transfer pricing method to justify prices in intra-group transactions;

  • Calculation of the arm’s length market range.

*Please note that on 1 July 1 2023, a new "black list" of the Ministry of Finance came into force - 51 "unfriendly jurisdictions", including the United States, European Union countries, Great Britain, Switzerland and others, so the transactions with independent companies in states from the “black list” will be equated to controlled transactions for transfer pricing purposes in accordance with Article 105.14 of the Russian Tax Code in case the threshold is exceeded.