Сlarifications On Intra-group Services: Key Takeaways

On 6 August 2020, the Russian Federal Tax Service published Letter No. SHU-4-13/12599@ "On certain issues regarding taxation of intra-group services" (the "Letter") addressed to local tax authorities. The Letter sets out key principles to guide tax audits of intercompany services acquired by Russian entities from foreign group companies:

Factual proof and non-duplication of intra-group services

The Letter recommends that local tax authorities conduct a comprehensive review of the documents provided by Russian taxpayers. The list of documents establishing factual proof of the services is not exhaustive. Taxpayers are permitted to provide documents drawn up in accordance with Russian law or according to customary business practices in a foreign jurisdiction if the services have been provided by a foreign entity.