Changes in transfer pricing control

The Tax Code of the Russian Federation has been amended to tighten control over transfer prices from 2024. We describe the most significant changes for companies conducting transactions with non-residents.Read more


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

Contents

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

Details

Date & Time

05.03.2024
15:00-16:45 (MSK)

Admission

Free

Language

Russian

Platform

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)

Submission of a country-by-country report by a Russian organization to the Federal Tax Service of the Russian Federation

The country-by-country report is a part of the three-tiered transfer pricing documentation of an international group of companies (MNE Group).Read more


Transfer pricing: the impact of expanding the list of offshore jurisdictions on the obligations of taxpayers conducting transactions with residents of offshore zones

On July 1, 2023, the Order of the Ministry of Finance of Russia No. 86n of June 5, 2023, "On the Approval of the List of States and Territories Granting Preferential Tax Treatment and/or Not Requiring Disclosure and Provision of Information in Financial Transactions (Offshore Zones)" came into effect. The list now includes 91 offshore zones, including EU countries, the USA, Japan, Canada, Australia, and others.Read more


The ministry finance has updated the tax haven blacklist en kons

The Ministry of Finance has updated the tax haven blacklist

The update was published on June 15, 2023 and comes into force on July 1, 2023. The new version of the blacklist is composed of 91 states (40 before the update) most notably including USA, United Kingdom, Japan, France, Germany, Finland, etc.
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Transfer pricing benefits for sme labor costs en konsu outsourci

Transfer pricing, Benefits for SME, Labor Costs Optimization & Risks of Terminating Business in Russia

Details

Date and time

June 9, 2022, from 15:00 to 16:30

Admission

Free

Language

Russian

Platform

MS Teams

Speakers and topics

Olga Mazina

Director of Tax and Legal Consulting Department

Actual issues of transfer pricing for foreign companies

  • Legislative norms 2021-2022, latest changes
  • Reporting of international groups of companies
  • Eliminate transfer pricing risks
Download presentation (PDF)
Konsu - Evgeny Sumin

Evgeniy Sumin

Deputy Director of Financial Consulting and Audit Department

Small and medium-sized business entity status for companies with foreign participation

  • Procedure for inclusion in the register of SMEs, practical aspects
  • Benefits and preferences for SMEs in 2022
Download presentation (PDF)
Konsu - Анна Резникова

Anna Reznikova

Head of Labor and Migration Law Practice

Options to reduce financial costs for staff in the current economic situation

  • Change of work schedule
  • Increasing labor productivity
  • Staff optimization
  • Grant of leave
  • Reducing other expenses
  • Savings on fines
Download presentation (PDF)
Konsu - Valentin Orlov - Senior lawyer

Valentin Orlov

Senior lawyer

Risks arising for company and its management in case of terminating business in Russia

  • Violation of public obligations
  • Violation of obligations to contractors and employees of organization
  • Subsidiary liability of controlling persons for organization debts
  • Risk mitigation options for foreign management of companies in Russia
Download presentation (PDF)

Transfer pricing in simple terms

Have you ever done an internet search for “transfer pricing”? It is a rather dry and complicated subject, isn’t it? Let’s talk about transfer pricing in simple terms.Read more


New OECD Automatic Exchange of Tax Information

New Law to Simplify the Exchange of International Tax Information

The Russian Ministry of Finance has drafted a bill intended to build a legal base for international automatic exchange of tax information and information on financial statements. Tax authorities will oversee this new system.

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