Federal Tax Service of Russia explains the approaches to be applied to check the reasonableness of expenses for intra-group services
The key clarifications of the FTS on each criterion
On 6 August 2020, the Russian Federal Tax Service (hereinafter, the “FTS”) issued Letter No. SHU-4-13/12599@ "On Certain Issues of Taxation of Intra-Group Services", in which it clarifies to the lower tax authorities how to check expenses on intra-group services, in terms of their economic justification and the sufficiency of supporting documentation. The KPMG Review summarises the key clarifications of the FTS on each criterion and contains specific recommendations to businesses.