February, 2018: Introduction of “three-tiered” transfer pricing documentation

The Federal Law of 27 November 2017 № 340-FZ (hereinafter, the “Law”) supplemented Part I of the Tax Code of the Russian Federation (hereinafter, the “TC RF”) with provisions regarding submission by Multinational Enterprise Group (hereinafter, the “MNE Group”) of the so-called “three-tiered” Transfer Pricing Documentation (hereinafter, the “TPD”).

In particular, the Law has established the following new provisions:

  • Participants of the MNE Group, being Russian tax residents, shall notify the tax authorities of participation in the MNE Group (hereinafter, the “Notification”);
  • The TPD is divided into a Master File and a Local File;
  • A parent company of the MNE Group or an authorized participant of the MNE Group files a Country-by-Country report containing aggregated information about the whole MNE Group. If the parent company of the MNE Group or the authorized participant of the MNE Group has not filed the Country-by-Country report, then the tax authorities may request it from a Russian taxpayer who is a participant of the MNE Group.

Please find more information on “three-tiered” transfer pricing documentation in English and Russian alerts below.