The RF SAC Presidium position: the form of notification on controlled transactions

On 25 February 2014, the RF SAC Presidium set aside the RF SAC decision deeming the form of notification on controlled transactions approved by the FTS Russia compliant with the RF TC and returned the case for reconsideration (RF SAC Presidium Ruling No. 18588/13 of 25 February 2014). In the recently published ruling, the RF SAC Presidium made the following determinations, which may be significant for the application of transfer pricing rules…

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