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Transfer pricing

Reporting issues and transfer pricing documentation are among the most complex in interconnected companies' relationships - especially when companies are located in different countries. 

Companies that deal with related firms must (subject to legal thresholds for transaction amounts - you can find more information in our overviews) prepare and submit transfer pricing documentation annually:

  • notice of controlled transactions,

  • transfer documentation.

Transfer documentation is provided to the tax authorities upon their request and serves as the main confirmation of the market price level used in transactions with related companies.

In addition to the domestic reporting package, starting from 2018, Russian taxpayers who belong to international groups of companies (IGC) must prepare and submit three-level transfer pricing documentation (taking into account the statutory revenue thresholds according to the consolidated financial statements - for more details see our information reviews).

If the criteria are met, the company is obliged to prepare the following reporting forms:

  • notification of participation in the IGC;

  • country information:

  • IGC global documentation (Master file);

  • national documentation (Local file);

  • Country-by-Country Reporting.

Our specialists are highly qualified and have extensive practical experience in this area and will be happy to assist you in preparing and writing transfer pricing documentation.