FTS of Russia and PJSC MMC Norilsk Nickel conclude Russia’s first bilateral pricing agreement with a foreign state

KPMG Review

KPMG review, January 12 2021

On 24 December 2020, the Federal Tax Service (FTS of Russia) and PJSC MMC Norilsk Nickel announced the conclusion of a bilateral pricing agreement for tax purposes. This was for the first time in Russian tax practice that this kind of agreement, involving a foreign tax agency – the Finnish Tax Administration – had been concluded. The agreement was announced by Head of the FTS of Russia, D.V. Egorov, and President of PJSC MMC Norilsk Nickel, V.O. Potanin, and published on the website of the FTS of Russia.

The bilateral agreement, concluded with the support of KPMG professionals, governs the pricing procedure and the procedure for applying transfer pricing methods to the controlled export transactions of PJSC MMC Norilsk Nickel in relation to its delivery of products to Finland. The FTS of Russia and the Finnish Tax Administration provided the basic parameters for the agreement which will now be applied for tax purposes by both the Russian and the foreign company of the Group.

Our KPMG professionals will be delighted to answer at length any questions you may have in relation to this, help you obtain unilateral and bilateral pricing agreements, support you during the mutual agreement procedure process, and advise you on any other issues associated with the application of transfer pricing laws. For more details about our services, go to our KPMG TP page.