On 14 March 2022, the Federal Tax Service (FTS) published guidance (Letter No. ШЮ-4-13/2724) stipulating that the application of sanctions against Russian individuals and legal entities may adversely affect the economic conditions of the transaction parties, taxpayers may need to sell their products at a discount for export, resulting in a loss in the transaction.
In this regard, the Federal Tax Service of Russia will take into account these circumstances and their impact on the terms and results of transactions recognized as controlled and when considering applications for advance pricing agreements.
