Comprehensive support on transfer pricing matters in respect of transactions between related parties.
The stages of service provision are determined individually. Depending on the client’s situation, work may start from a stage other than the first one: if the scope of controlled transactions has already been determined, the notification has been prepared, or part of the analysis has been completed earlier, we join the process at the required stage and take on only those tasks that are actually necessary.
Stage 1 — Determining the scope of controlled transactions (the main analytical stage that determines further work)
1. Consultation on transfer pricing methodology
- analysis of the group structure and the nature of intragroup transactions;
- assessment of related-party criteria;
- analysis of the applicability of the criteria for transactions to be treated as controlled;
- identification of potential tax risk areas.
2. Determining the scope of controlled transactions
- analysis of turnover between related parties;
- assessment of threshold values;
- classification of transactions by type (goods, works, services, loans, intangible assets, etc.);
- determination of the list of transactions to be included in the notification and documentation.
3. Selection of the transfer pricing methodology
- analysis of the functional profile of the parties (FAR analysis);
- selection and substantiation of the method for determining the arm’s length price level;
- determination of the tested party;
- selection and agreement of financial indicators.
4. Selection of information sources
- determination of sources of comparable data;
- selection of OKVED / TN VED / OKPD2 codes, if necessary.
As a result, you receive an opinion with recommendations on the methodology for substantiating the arm’s length price level.
Fee — RUB 325,000.
Timing — up to 20 business days.
Stage 2 — Preparation and filing of a notification of controlled transactions
If the notification is not filed on time or contains inaccurate information / is completed with errors, a penalty of RUB 100,000 applies (Article 129.4 of the Tax Code of the Russian Federation). Exemption from liability is possible if an amended notification is filed before you become aware that the tax authority has established a violation of the requirements of paragraph 2 of Article 105.16 of the Tax Code of the Russian Federation.
The scope of services at the second stage includes:
- preparation of the list of controlled transactions;
- grouping of standard transactions;
- preparation of the structure of Sections 1A and 1B;
- verification of the correctness of codes, transaction attributes, and grounds for controlled transaction status;
- generation of the notification file in the prescribed format and testing of the notification using the Russian Federal Tax Service validation software to identify possible issues;
- methodological support for filing.
As a result, you receive a prepared and verified notification of controlled transactions for 2025.
Timing — determined based on the first stage. The filing deadline for the notification is May 20.
Fee — calculated individually and depends on the scope of transactions determined at the first stage (indicatively, from RUB 75,000 per notification), as well as on:
- the number of legal entities included in one notification;
- the number of lines in Section 1B (the number of separate transaction types);
- the homogeneity of transactions (standard supplies / services / loans or diverse transactions);
- the need to adjust primary data;
- the complexity of the intragroup settlement structure.
Stage 3 — Preparation of transfer pricing documentation
The penalty for failure to provide documentation in respect of a specific transaction (group of homogeneous transactions) is RUB 500,000 (Article 129.11 of the Tax Code of the Russian Federation).
Description of the group and ownership structure
- ownership structure;
- description of the group’s activities;
- description of value chains.
Functional and risk analysis
- description of the functions of the transaction parties (procurement, logistics, marketing, distribution);
- analysis of assets used, including intangible assets;
- economic characteristics of transactions;
- allocation of commercial, logistics, and market risks between the parties.
Selection and substantiation of the transfer pricing method
- analysis of the applicability of transfer pricing methods;
- selection of the optimal method (with a focus on the transactional net margin method);
- substantiation of the impossibility of applying alternative methods.
Economic analysis
- selection of comparable independent companies / transactions;
- formation of a sample based on available information databases;
- calculation of the arm’s length range of profitability indicators;
- verification of whether the company’s actual indicators correspond to the arm’s length level;
- calculation of adjustments, if necessary.
Preparation of transfer pricing documentation
- preparation of documentation for each controlled category of transactions and preparation of appendices;
- description of the product market, if necessary;
- preparation of the document in a format ready for submission to the Federal Tax Service of the Russian Federation.
Work result — a complete set of transfer pricing documentation.
Fee — from RUB 625,000.
Additional services that may be provided if necessary
- support in connection with transfer pricing requests from the Federal Tax Service;
- preparation of explanations and responses to tax authority requests.
Fees and timing — to be agreed separately.
