Transfer pricing

Elimination of transfer pricing risks

Companies are not subject to fines if they submit transfer pricing documentation.
We offer full support for preparation of transfer pricing documentation and for tax audit preparation.

Our transfer pricing services:

Identification of related entities and controlled transactions;
Business overview and selection of appropriate transfer pricing method;
Comparative analysis of transfer prices, including market analysis and calculation of corporate indicators;
Preparation and updating of transfer pricing documentation;
Preparation of report on controlled transactions.

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Transfer pricing requirements in Russia

Russian companies concluding transactions with related foreign entities (so-called controlled transactions) must submit documents to tax authorities for verification of the prices applied in such transactions. If such prices are not in line with market level, this could indicate an understatement of payable taxes. Below we described all the requirements, deadlines and our transfer pricing services.

Risk of price verification in group:

International trade of commodities;
Offshore transactions;
Companies with high turnover under controlled transactions.

Transfer pricing deadlines

March 28 – deadline for submission of profit tax return. Tax adjustments rectifying any discrepancy between transfer prices and market level should be specified in such tax return;
May 20 – deadline for submission of reports on controlled transactions;
June 1 – the beginning of tax audits of controlled transactions. Transfer pricing documentation justifying the prices applied in controlled transactions should be prepared and ready by that time. Companies must submit to tax authorities transfer pricing documentation within 30 days of receipt of request from tax authorities.

Penalties for understated tax

If it is found during a tax audit that the tax base was understated because transfer prices were not in line with market prices, tax authorities will then be entitled to collect unpaid taxes, as well as impose a penalty

Penalty is 40% on the unpaid tax amount

Preparation of 3-tiered transfer pricing documentation

Companies that are members of international companies with a total turnover of more than €750 million must provide reporting:

Notification of participation in an international group of companies.
3 levels of reporting on transfer pricing:
- Country report;
- Global documentation;
- National documentation.

More detailed information for companies that need to provide 3-level documentation.

Elimination of transfer pricing risks

Companies are not subject to fines if they submit transfer pricing documentation.
We offer full support for preparation of transfer pricing documentation and for tax audit preparation.

Our transfer pricing services

Identification of related entities and controlled transactions;
Business overview and selection of appropriate transfer pricing method;
Comparative analysis of transfer prices, including market analysis and calculation of corporate indicators;
Preparation and updating of transfer pricing documentation;
Preparation of report on controlled transactions.

Our experts in transfer pricing

All our specialists have extensive experience in tax consultation, transfer pricing analysis and preparation of documentation according to international standards developed by the OECD and according to Russian tax law.