Key Transfer Pricing Changes from 1 January 2024
FBK Legal has drawn up an overview of transfer pricing amendments to the Russian Tax Code.
Key amendments include:
For more details on specific amendments and FBK Legal lawyers’ tips see here.
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.
