The Russian Federation joining the World Trade Organization and adopting comprehensive transfer pricing regulations were significant developments in 2012. The former event is expected to increase the volume of cross-border trade with Russia, while the latter may prompt multinational corporations (MNCs) operating in Russia to focus their attention on the pricing of intercompany transactions involving the Russian affiliates. In this NERA brief, Vice President Dr. Vladimir Starkov describes how the Russian Tax Code treats royalties paid by Russian taxpayers to foreign taxpayers, management services fees and technical assistance fees in Russia, and engineering and development activities in Russia.