In March 2020, the Russian Ministry of Finance (MoF) released an amended version of a draft law to improve tax control over prices and procedure for entering into advanced pricing agreements (APA). The draft measures are expected to be adopted in 2020 and effects from 1 January 2021.
The amendments included in the draft legislation that provides an option for a unilateral APA, if following consideration of an APA draft, the Russian and foreign tax authorities fail to reach a mutual agreement. Place limits on tax audits of transactions covered by an APA, unless a decision has been made to conclude or deny the APA.
The APA time period would be 24 months from the moment an application is accepted, however, this consideration period would be extended to 27 months.
The time period for a taxpayer to provide additionally requested APA related documents would be limited to 10 business days from receipt of a request. The time period for supplying a revised APA draft and associated documents relating to a controlled transaction would be limited to 30 business days from receipt the request by the taxpayer.
