FTS has reminded taxpayers of obligations to file controlled transaction notifications and supporting transfer pricing documentation confirming market pricing, and warned of fines for non-compliance.
Russia’s Federal Tax Service (FTS) has reminded taxpayers that notifications of controlled transactions for 2025 must be submitted no later than 20 May 2026.
Under paragraph 8 of Article 105.15 of the Tax Code of the Russian Federation, taxpayers are also required to submit documentation confirming that prices applied in controlled transactions during 2025 correspond to market levels. The requirement applies to transactions involving oil and petroleum products, ferrous and non-ferrous metals, mineral fertilisers, precious metals, and precious stones.
The FTS said the documentation must be submitted to the Central Office of the Federal Tax Service of Russia after the notification of controlled transactions has been filed with the tax authority. The documentation may be submitted by post, in person through the mailbox, or electronically.
The recommended electronic submission format was approved by Order No. ED-7-12/505@ of the Federal Tax Service of Russia dated 4 June 2025 under KND 1184076.
The authority also warned of penalties for non-compliance. A fine of RUB 100,000 applies for late submission of the notification of controlled transactions for 2025. In addition, a fine of RUB 500,000 applies for the late submission or failure to submit the required transfer pricing documentation.
