Transfer pricing: changes in legislation from 2024. Inclusion of dividends in the customs value of goods: legal and practical aspects


02:36 Transfer pricing: changes in 2024 – Olga Mazina
03:05 Criteria of interdependence of parties
04:51 Definition of controlled transactions
06:10 Transactions equated to transactions with interdependent parties
07:30 Transactions involving interdependent intermediaries
08:50 Transactions with offshore persons
11:54 Notification of controlled transactions
14:48 Transfer pricing documentation
24:14 Dividend tax
26:19 Checks
31:07 Penalties for non-payment of taxes
33:07 Penalties for failure to report
35:28 International groups of companies
39:01 Recommendations
43:00 Inclusion of dividends in the customs value of goods: legal and practical aspects – Maxim Dmitriev
44:37 Applicable provisions of the EAEU TC and court practice
56:16 Which companies are at risk
57:45 How customs inspections are conducted
1:10:02 How to influence the results of a customs audit
1:13:38 Appealing the decision of the customs authority
1:15:13 Recommendations
1:19:30 Answers to questions
1:20:58 What adverse consequences may arise for a company if it fails to submit objections to the customs audit report?
1:21:59 If dividends are paid to the 100% owner of the LLC to a foreign individual, should the dividends increase the customs value of the goods?
1:25:22 Is there a formula that increases the customs value? Different amounts of dividends can be paid in different years
1:27:12 If a company has losses but falls under the criteria?
1:27:40 If we do not pay dividends to an interdependent foreign person, can a customs inspection come to us?
1:28:25 Question about safe harbor for interest on debt obligations


Date & Time

15:00-16:45 (MSK)






MS Teams

Speakers & Topics

Olga Mazina

Director of Tax and Legal Consulting Department

Transfer pricing: changes in legislation from 2024

  • Controlled transactions
  • Notification of controlled transactions
  • Transfer pricing documentation
  • Additional tax, tax on "dividends"
  • Powers of controlling authorities
  • Penalties
  • International groups of companies
Download presentation (PDF RU)
Maksim Dmitriev
Senior Lawyer

Inclusion of dividends in the customs value of goods: legal and practical aspects

  • Applicable provisions of the EEU TC and court practice
  • Which companies are at risk?
  • How is the customs audit conducted?
  • How to influence the results of a customs audit?
  • Appealing the decision of the customs authority
  • Recommendations
Download presentation (PDF RU)

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