The amendment regarding the limitation on attributing to CIT deductions expenses from related parties became effective retrospectively from January 1, 2023

Subparagraph 23 of Article 264 of the Tax Code has been amended to clarify that this limitation applies only to those persons who are registered in states with preferential taxation.
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Federal Tax Service explanations of control over expenses for intragroup services

Russian organizations with foreign participation often incur expenses for intragroup services, i.e. services provided by related foreign companies. Most Russian enterprises that are part of international groups of companies incur expenses for so-called management fees.
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