Recently, the Federal Law No. 340-FZ of 27 November 2017, amending the Tax Code in relation to the implementation of the international automatic exchange of financial accounting information and transfer pricing (TP) documentation of multinational corporations, was published on the Russian official Internet portal. The Law came into force from the day of its official publication.

The Law obliges members of multinational enterprise (MNE) groups with annual consolidated group revenue over RUB 50 billion (approximately USD 856 million) in the preceding fiscal year to submit to tax authorities a three-tier documentation, including a Country-by-Country Report, global documentation (Master File), and national documentation (Local File), as well as a notification on their membership in an MNE group.

Local File should be submitted for a calendar year whereas notification, CBC report and Master File are to be submitted for the taxpayer’s fiscal year.The deadlines are :

-The notification needs to be submitted within 8 months of the end of the fiscal year.

-In line with OECD standard, CbC report is exchanged automatically in cases where an information exchange mechanism is in place. Ultimate parent holding companies resident in Russia must file the CbC report within 12 months of the end of the fiscal year.

-Master File can only be requested by the tax authorities after 12 months from the end of the fiscal year.

-Local File can only be requested by the tax authorities on 1 June of the year following the calendar year when the controlled transactions occurred. Under a transitional rule, this period is extended to 31 December for 2018 and 2019 calendar years.