New transfer pricing rules
State Duma has recently passed in a first reading amendments and addenda to the Russian Tax Code concerning new transfer pricing rules. It is expecting that the federal law comprising these new rules will come into effect in the next year.
Current transfer pricing rules which are presented in the articles 20 and 40 of the Tax Code are not working because of some judicial difficulties in their structure. New transfer pricing rules’ authors assert that they took into account foreign countries experience (especially the European Union) in this area and the OECD recommendations concerning transfer pricing.
And now I am going to study this proposed law. If this issue is interesting for you, do not hesitate to ask me any questions.
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2 Responses to “New transfer pricing rules”
Comment from Evgeny
Time April 28, 2010 at 6:40 pm
As a practicing tax lawyer in Russia I can say that neither taxpayers (business) nor tax authorities are not prepared to implementation of these rules. I am sure we will have a lot of different conflicts connected with the new law. Some of my colleagues are expecting huge amount of work.
Comment from Alex@ Transfer Pricing Watch
Time April 28, 2010 at 6:20 pm
I think overall it is still questionable whether Russia will be prepared to properly implement these new rules. I think it is also important to ask whether tax officials will gain the necessary knowledge and experience in making transfer pricing adjustments under the rules?