Deadline: Notice of controlled transactions

Dear Clients and Partners,

Please note that May 20, 2022 is the deadline for the submission of notification for the controlled transactions performed during 2021.

Controlled transactions include, inter alia, the following:

 Cross-border transactions between affiliated companies exceeding annual threshold of 60 million rubles. The threshold was increased in March to 120 million rubles, however, we believe that the amendment does not apply to transactions performed during 2021;
 Transactions between Russian affiliated companies exceeding annual threshold of 1 billion rubles (if additional requirement prescribed by the Tax Code are met).

Furthermore, starting from June 01, 2022, the tax authorities are entitled to request from the taxpayers transfer pricing documentation, which confirms that the prices applied in controlled transactions are arm’s length. The taxpayer has 30 days to prepare the transfer pricing documentation after the request from the tax authorities.

Since the TP documentation usually requires overall description of the controlled transactions and market study, we recommend our clients to prepare the documentation in advance.

Timur Nurmukhametdinov
Manager, Tax Advisory & Audit
+7 916 032 81 68
T.Nurmukhametdinov@bellerage.com