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Transfer Pricing

Transfer Pricing

Preparation of documents

New rules on transfer pricing have taken effect in 2012 in Russia. The new law replaced clauses 20 and 40 of the Tax Code of the Russian Federation with the new section V.1. "Related parties. General provisions on prices and taxation. Tax control over the transactions between the related parties. The pricing agreement".

The changes in the rules on transfer pricing have affected most parts of business community that carry out their activities through a group of related parties, since the law has significantly extended the list of grounds according to which the parties can be recognized as the related ones as well as the list of the controlled transactions.

Under the new law, Russian taxpayers who belong to the group of companies (holding companies) that are inter-related with other local and foreign entities and who enter into controlled transactions with them must prepare and submit transfer pricing accounts to the tax authorities.

Reports on transfer pricing include:

  • Notices about controlled transactions;
  • Documents on transfer pricing.

A taxpayer is obliged:

  • To submit the Notice about controlled transactions to the tax authorities by 20th of May (of the year following the calendar year when the controlled transactions were carried out);
  • To submit the Documents on transfer pricing within 30 days of the request from tax authorities.

Korpus Prava acts as an outsourced advisor that has experience in designing transfer pricing documents and implementation of transfer pricing structure for minimizing tax risks arising from the relationships of the related parties.

The process of designing transfer documents includes the following stages:

1. Inventory of controlled transactions and industry analysis.
2. Functional analysis and selection of price justification method.
3. Economic analysis and conducting a profitability comparison analysis.
4. Financial analysis.
5. Preparation and submission of transfer documents.

Advantages of choosing Korpus Prava services:

  • An international team of experts;
  • European partners;
  • High professional standards;
  • Many years of experience and efficient working methods;
  • Specialised software;
  • Good value for money;
  • Free consultations during project implementation (tax and legal advice).

Client recommendations can be provided on request.