On 1 January 2024, sweeping changes to the Transfer Pricing regulation (the “Law”*) came into force, requiring Russian taxpayers to expand their Transfer Pricing (TP) compliance and reassess their risks associated with controlled transactions.
Here are the main changes:
In addition, the Law introduces withholding taxation of income received by foreign companies from intra-group work and services. Such income is taxed at a rate of 15% from 1 January 2024.
At the same time, the Law partially and selectively restores certain benefits under the previously suspended DTTs with “unfriendly” states, which can be used until 31 December 2025.
* In Russian
Read more in our review
For further information, please contact:
Maria Kabanova
Counsel, International Tax
[email protected]