New rules of tax control over transfer pricing. FBK Legal lawyers spoke at the meeting of Russian Managers Association

On September 27, 2011 a round table discussion was arranged by Committee for Tax and Legal Regulation at the Russian Managers Association to discuss novelties in the field of control over transfer pricing.?Galina Akchurina, Head of FBK Legal Tax Litigation Practice and Tatiana Matveicheva, Head of FBK Legal Tax Advice Practice spoke at the meeting.

Galina Akchurina drew attention to poor quality of legal drafting methodology of new Russian Tax Code regulations, including those containing description of controlled transactions. Particularly poor are formulations concerning cases when it is necessary to exceed threshold amount of revenue to recognize transactions as controlled. “Problems also stem from vagueness of law regarding other conditions of transaction referring to controllable”, expanded Tatiana Matveicheva. She reminded that in terms of a whole range of transactions the taxpayer is obliged to inform the controlling authorities.

Representatives of Russian Federal Tax Service and of a number of leading Russian law firms took part in the discussion. Meanwhile representatives of international law firms told about their experience of applying transfer pricing in other countries.