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 | email@example.com
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