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Russian Ministry of Finance improves transfer pricing


The Ministry of Finance of Russia has proposed amendments aimed at improving the control of transfer pricing.

A draft law introducing amendments to the Tax Code has been prepared, providing for the possibility of applying the pricing methods of a foreign state when the contract concludes pricing agreements with the participation of the competent authority of the corresponding state.

The draft also clarifies the conditions for recognizing transactions as controlled. This mainly relates to foreign trade transactions, as well as the transactions between related parties with the participation of an agent.

The text of the project proposes the improvement of the procedure for conclusion of a pricing agreement. In particular, the time limits for consideration of a taxpayer’s application and documents when concluding an agreement on foreign trade transactions are extended and the specifics of concluding such an agreement are provided if the taxpayer’s counterparty submits a similar application to the competent authority of a foreign country. The draft law supplements the grounds for making a decision to refuse to conclude a pricing agreement.


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