02.02.12 Peculiarities of controlled transactions to be explained.
(Letter of Tax and Customs Tariff Policy Department of the Finance Ministry of Russia N 03-01-07/5-14 “On taxation of transactions between associated parties”, dated 28.11.2011)
А new procedure for monitoring transfer prices was introduced on 1st January, 2012.
The Letter clarifies that taxpayers are obliged to inform tax authorities about controlled transactions made in the calendar year.
Information on pricing methods in such transactions is not subject to disclosure.
When checking the transactions between related parties, FTS of Russia can use a different method (combination of methods).
The condition is a proof of the fact that the method (a combination thereof) used by the taxpayer, does not allow to determine the comparability of the commercial and (or) the financial conditions of the controlled transaction with the terms of compared transactions between non-interdependent persons. In this case methods provided by the Tax Code of Russia are used.
At the request of tax authorities the taxpayer shall submit the documents that contain information about the methods applied. The taxpayer has the right to submit documentation supporting the comparability of the above-mentioned conditions of the controlled transaction and concluded by non-interdependent persons.
A profound character of the documents shall reflect the complexity of the transaction and formation of its price.
The Letter also clarifies the issues of applying the method of comparable cost-effectiveness and a cost-based method.
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