Preparation of three-level documentation

Our specialists have extensive experience in writing transfer pricing documents with obligatory individual approach to the requirements of each client.

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Obligation to submit three-level documentation

Since 2018 Russian taxpayers that are members of international groups of companies (hereinafter referred to as IGCs) must prepare and submit three-level transfer pricing documentation.

This obligation arises for those IGCs

that, based on the results of the financial year preceding the reporting year, received consolidated revenue equivalent to 750 million EUR or more (if the parent company is located outside the Russian Federation, the threshold may be different).

What reporting forms will need to be prepared?

If the above mentioned criterion is met, the company is obliged to do:

1) Notification of participation in the IGC
2) 3 levels of transfer pricing reporting:
– Global documentation on the IGC (in international practice Master file)
– National documentation (in international practice Local file)
– Country report (in international practice Country-by-Country Report)

We will prepare documentation that will successfully pass an external audit

We will prepare the report for you or help you to prepare it yourself

We will analyze the need and form of submission of reports. We will provide support in requesting information from the parent company. We will provide templates. We will provide training for employees.