On January 31 2012 it has been published that, the Russian Federal Tax Service published a letter No.ОА-4-13/85 “On Conclusion of Advanced Pricing Agreements for the tax purposes” dated 12 January 2012 on its official website.
The letter is a recommendation, and although it is not binding for taxpayers, it provides guidance on the practical realization of an Advanced Pricing Agreement (APA) tool provided by Chapter 14.6 of the Tax Code.
The Letter generally follows the common international practice for concluding APAs. In particular, the tax authorities directly refer to the fact that they will follow the principles for concluding APAs provided by the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations.
