In this article from BNA Bloomberg’s Tax Management Transfer Pricing Report, NERA Vice President Vladimir Starkov examines recently issued documentation guidance in Russia. The Russian Federal Tax Service, in a letter issued 3 September 2012, expanded on the transfer pricing documentation guidance in the overall transfer pricing rules issued in July 2011, specifying not only which types of transactions need to be documented, but also that most transactions need to be documented separately rather than aggregated. The documentation requirements apply to all transactions considered “controlled” under the Russian Tax Code if the annual volume of such transactions exceeds the defined minimum threshold. Mr. Starkov describes these minimum threshold requirements, as well as the types of information requested and when the information must be submitted and updated.
Reproduced with permission from Tax Management Transfer Pricing Report, Vol. 21 No. 10, 9/20/2012. Copyright 2012 by The Bureau of National Affairs, Inc. (800-372-1033) http://www.bna.com