A major tax package introducing amendments to the Russian Tax Code has recently passed the third reading in the State Duma.
Increasingly under the spotlight, the proposed measures providing for a major clampdown on the transfer pricing rules are:
Read on for a more detailed review.
Increasingly under the spotlight, the proposed measures providing for a major clampdown on the transfer pricing rules are:
- to classify TP adjustments for controlled transactions with non-residents as dividends subject to withholding tax;
- to expand the related party criteria;
- to calculate arm’s length prices as the median of the arm’s length range;
- to expand the scope of reportable information on controlled transactions;
- to increase the fines for transfer pricing breaches;
- to change the safe harbor interest income/expense rates.
Read on for a more detailed review.