Russia’s Federal Tax Service (FTS) issued Letter No. ШЮ-4-13/2827@ on 13 March 2025 about the notification of controlled transactions. It clarifies that from 2024, taxpayers must disclose the transfer pricing method used to justify the market (arm’s length) price of a controlled transaction.
Additionally, the transfer pricing method must be included in the transfer pricing documentation provided to the tax authority upon request.
A penalty of RUB 100,000 applies for late or inaccurate notifications. Taxpayers failing to submit documentation regarding a specific transaction or a group of similar transactions within the established time period will incur a penalty of RUB 500,000.
