Russian Tax Authority Issued Recommendations on Transfer Pricing Documentation

Russian Tax Authority Issued Recommendations on Transfer Pricing Documentation

 

The detailed recommendations on documentation preparing for the purpose of tax control were published on the official web-site of the Russian Federal Tax Authority.

The recommendations are included into the letter of the FTA as of 30.08.2012 № OA-4-13/14433@. They were prepared on the basis of the Tax Code provisions and international practice. The recommendations are designed to help taxpayer in preparing of transfer pricing documentations for lowering the burden of that documentation and making it consistent with current legislation.

The taxpayers’ liability to provide pricing documentation of the tax authority’s request is stated by clause 105.15 of the Tax Code. It is important to note that ‘documentation’ in the terms of transfer pricing means research into the documents of a taxpayer proving or not proving that the prices of transactions with related parties are at the market level.

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