Preparation of a Master File in accordance with BEPS13 requirements

Who should submit a Master File?

  

If the ultimate parent entity of a multinational enterprise group (MNE Group) is a tax resident of the Russian Federation, it is necessary to prepare a Master File in accordance with the requirements of the RTC, check the requirements for a Master File and the deadlines for its filing in all tax jurisdictions of the MNE Group’s presence, adapt it and translate it into a foreign language (if necessary).

If the ultimate parent entity is not a tax resident of the Russian Federation but has subsidiaries in the Russian Federation, the latter should request a Master File from the ultimate parent entity of the MNE Group, review it for compliance with the requirements of the RTC and translate it into Russian. In accordance with clause 3 of article 105.16-3 of the RTC, if a Master File has already been submitted by any constituent entity of an MNE Group in the Russian Federation, the tax authorities do not have the right to request it from another constituent entity of the MNE Group in the Russian Federation.

A Master File is compiled in any format taking into account the requirements for the content of information stipulated by the provisions of article 105.16-4 of the RTC.

The deadline for submitting a Master File is within 3 months from the moment of receiving the tax authorities’ request that can be sent not earlier than 12 months and not later than 36 months after the reporting period ends.

Since 2020, failure to submit a Master File results in a fine of RUB 100,000.

Our services

  

  • Turnkey preparation of a Master File on an MNE Group in accordance with the requirements of the RTC, as well as in accordance with the requirements of foreign laws.
  • Adaptation of a Master File prepared by an MNE Group in accordance with the requirements of the RTC, including:
    • Review of a Master File for compliance with the requirements of the RTC.
    • Adaptation/revision of a Master File based on the results of a review in accordance with the requirements of the RTC.
  • Professional translation of the prepared Master File into the Russian and foreign languages.

Team

  

The KPMG Transfer Pricing team will be pleased to assist in the preparation, adaptation and translation of a Master File in accordance with the requirements of the RTC. Since 2012, our team has been preparing transfer pricing documentation. The team consists of about 100 specialists from Moscow, St. Petersburg, Nizhny Novgorod, Ekaterinburg, Voronezh, Novosibirsk and Minsk, who have extensive expertise in transfer pricing, accounting and tax accounting (RAS and IFRS).