Key Transfer Pricing Changes from 1 January 2024

01 February 2024
FBK Legal has drawn up an overview of transfer pricing amendments to the Russian Tax Code.

Key amendments include:

  • Three additional criteria for recognising parties as related have been added to Article 105.1, clause 2 of the Tax Code of the Russian Federation.
  • The criteria for recognising transactions as controlled have been changed.
  • The methods for calculating TP adjustments have been changed, and secondary TP adjustments have been introduced.
  • The intervals of interest rate limits for debt liabilities have been reduced.
  • The scope of information to be disclosed in TP reporting and in the notification on controlled transactions has been expanded.
  • Liability has been tightened for underpayment of taxes due to deviation of prices from the arm’s length level in transactions with foreign counterparties (the penalty amount was increased to 100% of the unpaid tax), and penalties have been significantly raised for the failure to submit a notification on controlled transactions, and notification on participation in MNCs, etc.
  • The pricing agreement has been made more attractive.
  • Special rules have been introduced for taxpayers who carry out foreign trade transactions involving commodities.


For more details on specific amendments and FBK Legal lawyers’ tips see here.
Subscribe to our news
Get the best news in a weekly email
be22
1
7
2
8
5
Benchmark litigation
6
3
Forbes
4