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Transfer Pricing Services

PwC Russia’s transfer pricing team supports multinational corporations and large Russian groups in confirming that the prices they charge in intercompany transactions are at an arm’s length for tax purposes.

Our team consists of over 30 people and includes experienced TP generalists, industry and special area experts (such as financial transactions, commodity markets and IP transactions) as well as specialists in TP big data analysis and visualization. Our leaders work with Russian lawmakers and tax administration to support our clients and advance the transfer pricing agenda.

As a team, we are integrated into PwC global transfer pricing network, so we draw on the expertise of our colleagues in Americas, Europe and Asia and can support your projects across the globe. We use in our work special-purpose TP software and we offer the IT tools to our clients to enhance their internal TP capabilities.

How we can help

TP risk assessments and data analytics

  • TP diagnostics

For our new clients we offer TP diagnostics, which allows to pinpoint key TP challenges and plan further mitigation work Traditional diagnostics calls for a set of interviews and an inquiry into the client’s historic financial and transactional data, and it works best for businesses with large and complex transactions. Our new “express” diagnostics offering requires our clients to answer PwC’s proprietary web questionnaire and is very time and cost efficient.

  • TP data services and solutions

In our analysis we take advantage of big data and explore, study, interpret and present to clients their transactional and other supporting data in a form of informative dashboards, charts and graphs. This allows our clients to see and fix outliers (e.g. unusually high or low margins or prices), compare their margins vs their peer group and model the impact of economic downturns (such as the current COVID crisis) on arm’s length margins using historic regression data.

“Forward looking” TP products

  • Designing TP models and methodologies

We help the clients design economically sound TP models across the whole value chain to ensure that each component of their business (manufacturing sites, trading entities, financial, investment and IP hubs) is properly remunerated. We describe the models in structured TP policies and methodologies, which the clients use for setting prices and defending them in front of the tax administrations.

  • Special area consulting

We do projects in special areas which require more than just general TP experience. We advise clients on the TP aspects of foreign currency financing, cash pooling and commodity transactions, including choice of benchmarks, quotation periods and complex comparability adjustments.

  • Advance pricing agreements

Our firm was a part of the first ever Russian APA back in 2012, and we have unique experience of going through a bilateral APA for our client involving Russia’s and a foreign country’s tax administrations. We support client throughout the whole APA process starting with analysing the contemplated transaction, developing the APA negotiating strategy, drafting the documentary package for the APA submission, and partaking with clients in the negotiations process with the authorities.

TP compliance and tax controversy resolution “Forward looking” TP products TP

  • TP compliance

Our service ranges from preparing local statutory TP forms to designing sophisticated master files and CbCRs covering dozens of jurisdictions. In cross territory projects we use PwC’s proprietary GCD Reporter Tool, which allows us to coordinate the work of territory teams, use consistent templates, visuals and language in TP reports prepared for same client in multiple territories, ensure version control and centralised roll out of updates based on client’s feedback.

  • Audit, pretrial and trial support

We assist Russian and foreign companies in communication with the Russian state authorities in respect of complex regulatory issues and TP audits (including support in prelitigation communication with tax authorities and tax disputes in the field of TP). We provide comprehensive support in litigation, assisting during pre litigation stages by resolving issues arising from tax audits on transfer pricing matters.

How we can help?

We support our clients on all stages of project lifecycle, from strategy to execution. We do risk assessments and diagnostics to understand our clients’ current standing on TP; help the clients to design sound TP models; develop structured TP policies and methodologies; and prepare TP documentation and related statutory filings.

We help clients in their negotiations with the tax administrations and, if the client undergoes a TP audit, we support them during the audit and, if it comes to that, on a pre-trial and trial stages. We specifically focus on “forward looking” products, such as advance pricing agreements and TP models and policies, since these help our clients to proactively address potential TP challenges, which is par ticularly relevant in the current economic and fiscal environment.

  • TP diagnostics

For our new clients we offer TP diagnostics, which allows to pinpoint key TP challenges and plan further mitigation work Traditional diagnostics calls for a set of interviews and an inquiry into the client’s historic financial and transactional data, and it works best for businesses with large and complex transactions. Our new “express” diagnostics offering requires our clients to answer PwC’s proprietary web-questionnaire and is very time and cost efficient.

  • TP data services and solutions

In our analysis we take advantage of big data and explore, study, interpret and present to clients their transactional and other supporting data in a form of informative dashboards, charts and graphs. This allows our clients to see and fix outliers (e.g. unusually high or low margins or prices), compare their margins vs their peer group and model the impact of economic downturns (such as the current COVID-crisis) on arm’s length margins using historic regression data.

  • Designing TP models and methodologies

We help the clients design economically sound TP models across the whole value chain to ensure that each component of their business (manufacturing sites, trading entities, financial, investment and IP hubs) is properly remunerated. We describe the models in structured TP policies and methodologies, which the clients use for setting prices and defending them in front of the tax administrations.

  • Special area consulting

We do projects in special areas which require more than just general TP experience. We advise clients on the TP aspects of foreign currency financing, cash pooling and commodity transactions, including choice of benchmarks, quotation periods and complex comparability adjustments.

  • Advance pricing agreements

Our firm was a part of the first-ever Russian APA back in 2012, and we have unique experience of going through a bilateral APA for our client involving Russia’s and a foreign country’s tax administrations. We support client throughout the whole APA process starting with analysing the contemplated transaction, developing the APA negotiating strategy, drafting the documentary package for the APA submission, and partaking with clients in the negotiations process with the authorities.

  • TP compliance

Our service ranges from preparing local statutory TP forms to designing sophisticated master files and CbCRs covering dozens of jurisdictions. In cross-territory projects we use PwC’s proprietary GCD Reporter Tool, which allows us to coordinate the work of territory teams, use consistent templates, visuals and language in TP reports prepared for same client in multiple territories, ensure version control and centralised roll out of updates based on client’s feedback.

  • Audit, pre-trial and trial support

We assist Russian and foreign companies in communication with the Russian state authorities in respect of complex regulatory issues and TP audits (including support in pre-litigation communication with tax authorities and tax disputes in the field of TP). We provide comprehensive support in litigation, assisting during pre-litigation stages by resolving issues arising from tax audits on transfer pricing matters.

Why us?

PwC TP practice network is the largest in the world by number of TP specialists, total revenue and geographical coverage which brings together 3,100 professionals in more than 90 countries. In close cooperation with our TP practices we’re well positioned to advise clients on developing TP compliant, tax-efficient structures that help to deliver best solutions to the clients at competitive price


Our expertise is recognised and honoured by authoritative international ratings and awards:

  • PwC Russia is constantly recommended in category transfer pricing (Tier 1) in World Transfer Pricing, a comprehensive guide to the world’s leading tax transfer pricing firms (2017 - 2020)
  • Natalia Kozlova , head of the TP practice at PwC, was personally recommended by the ranking as one the leading practitioners in transfer pricing in 2019 and 2020
  • PwC Russia is shortlisted for the ITR European Tax Awards as a Russia Tax firm of the year and Russia Transfer pricing firm of the year (2017 - 2020)

Our TP practice uses unique automatization tools, in particular:

  • Tools integrated in SAP accounting systems allowing to perform life analysis of margins in clients accounting systems
  • TP NOTA (TP Notification Analyzer) - a tool visualizing and analysing reportable controlled transactions and prices applied in structured but flexible dashboards
  • GCD Reporter globalDoc a TP documentation compilation tool allowing as a bonus to track a percentage of TP reports completion and exchange of information with clients in the course of the project
  • Web Express diagnostics tool, allowing to flag TP issues and determine directions to mitigate the identified risks
  • TP margins Analyzer - a tool allowing to analyse big data and present it dynamic dashboards
  • Our experts create process workflows allowing data enrichment from different sources, data cleaning, processing and presenting in a required way (including xml files, spreadsheets and dashboards)

Contact us

Natalia Kozlova

Natalia Kozlova

Partner, Transfer Pricing Services

Tel: +7 (495) 967 6184

Andrew Joshi

Andrew Joshi

Partner, Transfer Pricing Services

Tel: +7 (495) 232 5419

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