The Russian Ministry of Finance in late March 2020 released an updated version of a draft law, known in English as: “On amending part one of the Russian Tax Code to improve tax control over prices, and on the procedure for entering into advanced pricing agreements.”
The draft legislation is intended to optimise the procedure governing the conclusion of advance pricing agreements (APAs), to define the conditions when transactions can be regarded as controlled, and to introduce some other specific amendments to the provisions of the Russian tax law.
The draft measures are expected to be adopted in 2020 and have an effective date from 1 January 2021, so that the provisions would apply to transactions for which income and/or expenses will be recognised in accordance with Chapter 25 of the Russian tax law beginning from 1 January 2021.
The key amendments included in the draft legislation include items that would:
Other amendments would require taxpayers to conduct significant preparatory work in applying for an APA such as:
The draft law seeks to clarify several provisions regarding the definition of a controlled transaction. These amendments are intended to:
For more information, contact the Global Leader of KPMG’s Global Transfer Pricing Services:
Komal Dhall | +1 212 872 3089 | firstname.lastname@example.org
The KPMG logo and name are trademarks of KPMG International. KPMG International is a Swiss cooperative that serves as a coordinating entity for a network of independent member firms. KPMG International provides no audit or other client services. Such services are provided solely by member firms in their respective geographic areas. KPMG International and its member firms are legally distinct and separate entities. They are not and nothing contained herein shall be construed to place these entities in the relationship of parents, subsidiaries, agents, partners, or joint venturers. No member firm has any authority (actual, apparent, implied or otherwise) to obligate or bind KPMG International or any member firm in any manner whatsoever. The information contained in herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation. For more information, contact KPMG's Federal Tax Legislative and Regulatory Services Group at: + 1 202 533 4366, 1801 K Street NW, Washington, DC 20006.