Transfer Prices Documenting

According to the Russian transfer pricing legislation, as stipulated in Section V.1 of the Russian Tax Code, Russian companies and representative offices of foreign companies whose income is subject to taxation in the Russian Federation and which have controlled transactions are obliged to submit to the tax authorities notification on all such transactions and provide documentation on controlled transactions upon request of the latter.

In this regard, the KPMG team will be happy to provide you with the following services:

Transfer pricing rules can be used not only for documenting the concluded transactions but also for planning future transactions, as well as for diagnosing and forecasting intragroup prices. In this connection, the KPMG team is ready to offer the following additional services:

  • Timely diagnostics of the intragroup prices: identification and assessment of risks of non-compliance with transfer pricing rules and analysis of compliance of intragroup prices with the arm’s length level.
  • Development/revision of transfer pricing policies and minimization of identified risks (e.g., by changing the structure of supply chain and manufacturing operations, coordinating with counterparties and making amendments to current contracts).
  • Carrying out benchmarking studies to justify the level of applied prices/profitability level.
  • Development of a system for determining and monitoring prices within intragroup transactions.