We would like to remind you about the most important questions regarding Russian transfer pricing legislation for the year 2015 and the associated responsibilities of taxpayers.

1. 1
Accountor St. Petersburg
Shpalernaya Ul. 54
191015 St. Petersburg
+7 812 325 82 94
spb@accountor.ru
Timo Sivonen
Executive Director
+7 981 720 60 09
timo.sivonen@accountor.ru
Accountor Moscow
Sadovnicheskaya nab. 79
115035 Moscow
+7 495 788 00 05
moscow@accountor.ru
Samuli Pesu
Deputy CEO
+7 926 710 4361
samuli.pesu@accountor.ru
Transfer pricing reporting and documentation in 2015
We would like to remind you about the most important questions regarding Russian transfer pricing legislation for
the year 2015 and the associated responsibilities of taxpayers.
The related documentation listed below needs the time and involvement of experts. We would recommend that
you start your preparations early; this will help you to decrease your tax risks. Thank you in advance for your
prompt response.
1. Transfer pricing calendar 2015 and documents requested for statutory control:
20.5.2015 Deadline for tax declaration about controlled transactions for the year 2014
1.6.2015 From this date, state authorities can check the controlled transaction prices for the year 2014. The
taxpayer should prepare documentation to justify the market level of prices in controlled transactions, the so-
called transfer pricing documentation for the year 2014
31.12.2015 Last day an action can be instigated to check the controlled transaction prices for the year 2013.
The transfer pricing documentation for the year should be available
Please, pay attention to the following points:
• Year 2013: prices can be checked by the authorities if the cumulative volume of controlled transactions with
related non-residents for the year is more than 80 mln. rub.
• Year 2014: all controlled transactions with non-residents can be checked by the authorities. There is no
limitation anymore: this was only applied during the transitional period, 2012-2013.
2. Penalties
If the tax checking reveals discrepancies between the prices of the controlled transaction and the market price
level, which leads to an underestimation of taxes, the tax authorities may apply for a tax calculation of the market
prices, and impose a penalty. For the transitional period 2012-2013, there will be no penalties, only the extra tax
should be paid. From 2014 – a penalty will be charged equal to an additional 20% of the unpaid tax, and from
2017 the penalty will be 40% of the unpaid tax.
However, the taxpayer can be exempted from the penalty when they provide tax checking with the transfer
pricing documentation (Tax Code art.1292).
We would be glad to support you in 1) the preparation of the transfer pricing documentation and 2) transfer
pricing declaration for year 2014.
For more information, please contact:
2015_04_10
News
Samuli Pesu
Deputy CEO
Accountor Russia
Mobile: +7 926 710 4361
Office: +7 495 788 00 05
samuli.pesu@accountor.ru
Daniil Berlizov
Senior Business Development Manager
Accountor Russia
Mobile: +7 916 539 68 66
Office:+7 495 788 00 05 (242)
daniil.berlizov@accountor.ru

2. 2
Accountor St. Petersburg
Shpalernaya Ul. 54
191015 St. Petersburg
+7 812 325 82 94
spb@accountor.ru
Timo Sivonen
Executive Director
+7 981 720 60 09
timo.sivonen@accountor.ru
Accountor Moscow
Sadovnicheskaya nab. 79
115035 Moscow
+7 495 788 00 05
moscow@accountor.ru
Samuli Pesu
Deputy CEO
+7 926 710 4361
samuli.pesu@accountor.ru