Transfer Pricing

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Why is it important?

In July 2011, the Russian Parliament approved the law on the new Russian transfer pricing rules. The new rules are effective from 1 January 2012 and contain significant changes, including new transfer pricing methods, reporting and transfer pricing documentation requirements, special transfer pricing audits and penalties, and Advance Pricing Agreements.

Though the new rules are similar to the OECD Transfer Pricing principles, certain differences do exist. In particular, adjustments to decrease the taxable base are not technically allowed, and local comparables are preferred for benchmarking profitability of Russian companies. As a result, multinationals will have to think about if their global transfer pricing policies are acceptable and whether they need to tailor their documentation for use in Russia.

About our Transfer Pricing practice in Russia

The PwC Russia Transfer Pricing group consists of professionals who deal exclusively with transfer pricing issues. Our team is growing in response to the increasing importance of transfer pricing issues for Russia. We have successfully advised our clients on a number of major transfer pricing projects in the energy, mining and metals, retail and consumer, pharmaceutical, technology and telecom, and financial sectors. 

The magazine International Tax Review recognized PwC Russia as the European Transfer Pricing Firm of the Year in 2010 and 2011. PwC Russia has been awarded the title of Transfer Pricing Firm of the Year in Russia more often than any other firm in the country.

As a member of the PwC Global Transfer Pricing Network with over 1,500 fully dedicated transfer pricing professionals worldwide, we help our clients to address transfer pricing challenges in each country where they have business operations..

How can we help?

PwC Russia provides, among others, the following transfer pricing services:

  • Assisting in preparing for the new transfer pricing rules that are effective starting from 1 January 2012
  • Recommending improvements to existing pricing policies (supply chain transformation projects)
  • Justifying pricing methodology and arm’s-length nature of intra-company charges
  • Advising on structuring inter-company transactions (in particular, provision of IP rights)
  • Advising foreign multinational companies on tailoring transfer pricing policies for Russia
  • Designing and assisting in implementing trading and procurement structures
  • Advising on development of transfer pricing methodology and cost allocation models
  • Preparing transfer pricing documentation supporting arm’s length prices
  • Developing business processes and internal control systems to comply with the transfer pricing requirements
  • Assisting in resolving transfer pricing related disputes during tax audits

For further information, please contact our transfer pricing experts or your tax manager.

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