Transfer pricing

The Russian laws and regulations on transfer pricing have undergone significant changes since 1 January 2012 . A new type of tax reporting has appeared – notices of controlled transactions; the rules of controlling transfer pricing have changed significantly; likewise, there have been changes in the scope of parties subject to these rules.

You may be subject to transfer pricing control if you transact with:

• related parties;
• third parties from countries (territories) included, inter alia, into the List of Countries determined by the Russian Ministry of Finance in accordance with subitem 1 item 3 article 284 of the Russian Tax Code;
• third parties with the object of transactions being commodities of the world exchange trade falling into the following commodity groups: oil and oil products, ferrous metals, non-ferrous metals, mineral fertilizers, precious metals and precious stones.

Our experts have relevant experience in practical application of the transfer pricing regulations. Professional competencies, objectivity, accurate and reasonable approach to issues of any complexity of our experts are confirmed by our client references and high ratings.

We offer the following services with respect to transfer pricing:

• Assistance in preparing notices with respect to controlled transactions;
• Preparation of methodology of transfer pricing, justification of the methodology being used and of the conformity of current prices to the market prices with respect to controlled transactions;
• Preparation of documentation for controlled transactions in order to justify the market level of prices applied for taxation purposes;
• Development of documents regulating the procedure for generation of documentation and notices with respect to controlled transactions in accordance with legislation on transfer pricing;
• Development of regulations on communication between different departments of the company with respect to preparation of notices of controlled transactions and their submission to tax bodies, as well as with respect to preparation of transfer pricing documentation;
• Assistance to international companies with bringing their global transfer pricing policies in conformity with the Russian tax legislation;
• Advice on methodological issues of transfer pricing;
• Identification of risks of transfer pricing and advice on their minimization.

Our experience in transfer pricing shall help you implement an internal control system over transfer prices with minimal financial and time constraints; we shall help you organize fulfillment of new obligations with respect to transfer pricing in the most efficient way for the business.