Recent trends of transfer pricing rules in Russia

Recent trends of transfer pricing rules in Russia

We would like to inform you that on April 5, 2013, the President of the Russian Federation signed the draft legislation containing a series of changes meant to be introduced in the legislation on the tax control of prices.


In accordance with the given legislation, the main changes affect the transfer of terms for notice provision, the reclamation by the tax authorities of documentation and decision taking on the conduction of audits for the year 2012:

  • The term of notice provision has been transferred from 20 May, 2013 to 20 November, 2013;
  • Transfer pricing documentation for the year 2012 can be reclaimed by the tax authorities no later than 1 December, 2013 (the previous term was no later than 1 June, 2013);
  • Decisions on the conduction of tax audits regarding transfer pricing for the year 2012 are taken no later than 30 June, 2014 (the previous term was no later than 31 December, 2013).

Also, according to the given legislation, the provisions of Law 227-FZ on the control of transfer pricing shall not extend on deals/contracts for the provision of loans, credits (including trade and commercial credits), sureties and banking guarantees which had been concluded before 1 January, 2012, and the terms of which had not been altered after January 1, 2012.

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