Russian Federal Tax Service issued clarification on the requirements for filling notification in the case of certain controlled transactions
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Russian Federal Tax Service issued clarification on the requirements for filling notification in the case of certain controlled transactions

On 1 November 2013, the Federal Tax Service issued Letter No. OA-4-13/19652 providing detailed instructions as regards the completion of the notification regarding certain controlled transactions (transactions between the related parties as stated in105.14 of the Tax Code of Russia), as follows:

  • Cases when similar transactions with securities may be grouped together
  • Rules regarding the transactions whose price is expressed as a percentage
  • Rules regarding the transactions carried out by credit organizations with currency and precious metals
  • Rules regarding loan transactions
  • Rules regarding transactions with derivatives
  • Rules regarding transactions with promissory notes
  • Rules regarding transactions with permanent establishments of foreign entities (in particular, the Federal Tax Service pointed out that the party to a controlled transaction with a permanent establishment of a foreign entity should be deemed to be the foreign entity itself; therefore, information relating to the foreign entity itself should be provided in the notification)
  • Rules regarding agency transactions

According to article 105.16 of the Tax Code of Russia, taxpayers have to notify the tax authorities annually of all controlled transactions provided in article 105.14 of the Tax Code that were concluded during the previous calendar year.

 

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