Letter No 03-01-18/2080 issued by the Russian Finance Ministry on 22 January 2014 clarifies that some domestic transactions are to be subject to the transfer pricing rules as they are deemed to be controlled transactions for this purpose. These include a transaction in which one of the parties is subject to the Uniform Tax on Imputed Income (UTII) regime, but the other party to the transaction is not affected by that tax.
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