Dentons' Tax practice would like to remind you that, for
transactions completed in 2015, the notice of controlled
transactions must be filed with the tax authority at the
taxpayer's location (place of residence, registration) on or
before May 20, 2016, and taxpayers may be asked to provide
supporting documentation on transfer pricing ("Transfer
Pricing") starting June 1, 2016. The supporting documentation
must be submitted within 30 business days of when the Federal Tax
Service of Russia notice is received.
It should also be borne in mind that, although the Russian
Ministry of Finance has in effect admitted that its previous
clarifications, which allowed tax audit of pricing in arm's
length transactions (transactions which by law shall not be treated
as controlled) were in error (see Letter No. 03-01-18/35527 of June
19, 2015), the tax authorities continue to actively monitor prices
in such transactions.
