The Ministry of Finance of Russia has issued public letter No. 03-01-18/26965 in relation to transfer pricing documentation on July 11, 2013 that clarifies process for preparing and submitting transfer pricing documentation for a particular transaction to identify the appropriate transfer pricing method.
The Ministry of Finance points out that, pursuant to article 105.15 of the Tax Code, a taxpayer must submit transfer pricing documentation for a particular transaction (or a group of similar transactions) upon request of the federal authorities. The transfer pricing documentation may contain a set of documents or a single document prepared in any form and containing the information listed in the Tax Code.
Considering the provisions of the Tax Code, the Ministry of Finance has clarified that the transfer pricing documentation could be prepared either by the party to the transaction (or group of similar transactions), to whom the respective request is addressed by the federal authorities or by the counterparties to the transaction. However, the transfer pricing documentation should be submitted by the person who received the request from the federal authorities.
