Transfer pricing in Russia: what is the likelihood of an audit?
On 20 November 2013, for the first time Russian taxpayers should have filed with controlling authorities notifications on controlled transactions in accordance with the new transfer pricing rules. According to the Federal Tax Service, taxpayers filed 5,000 notifications with respect to operations performed in 2012. Notifications for 2013 must be filed by 20 May 2014.
According to the transition provisions, the tax authorities are entitled to initiate transfer pricing audits for 2012 within a seven-month period (from 1 December 2013 to 30 June 2014) and for 2013 within an 18-month period (from 1 June 2014 to 31 December 2015).
As was repeatedly noted by tax authorities, one of the principal aims of the notifications is to provide the tax authorities with the necessary array of preliminary information, which, together with other data on the activity of the company and its contractors accumulated by the tax authorities, will be used to decide whether to conduct a transfer pricing audit of the controlled transactions. In this regard, the criteria used to make such a decision is rather interesting…
Click on the link below to read the rest of the DLA Piper briefing.
News from DLA Piper
News from The Lawyer
Briefings from DLA Piper
DLA Piper has released the 29 September 2014 issue of its Health Alert, which focuses on judgments, legislation and reports in the health sector.
Facing the looming economic threat: third parties retain the right to intervene in threatened industrial action
Third parties have retained the recently acquired right to intervene to protect their interests in the face of threatened industrial action.
Analysis from The Lawyer
Shearman & Sterling is making its presence felt in the City, squaring up to magic circle firms and looking to muscle in on key relationships. Private equity house Bridgepoint is one outfit that has had its head turned by the US firm.
A new breed of lawyer is smoothing the path for companies entering emerging or unstable jurisdictions