The Russian Ministry of Finance (MoF) issued Guidance Letter No. 03-12-11/1/126454 on 27 December 2023, providing clarification on the application of Order No. 86n from 5 June 2023. This order expanded the list of states with preferential tax regimes for transfer pricing purposes, including EU countries, the United Kingdom, the United States, and others. The guidance explains that transactions with parties from listed states become controlled if exceeding RUB 120 million in a calendar year.
Although the Order became effective on 1 July 2023, its impact on listed jurisdictions will only apply from 1 January 2024, exempting transactions with newly listed states and territories from being considered controlled in 2023 based solely on the updated list.
