Russia: Offering New Transfer Pricing Deadlines
The Russian government has sent Draft Law No. 79859-6, which offers to set new transfer pricing deadlines for taxpayers for the second reading to the lower house of the Russian parliament. These changes may impact international businesses operating
See MoreRussia: VAT treatment of agency services in connection with alienation of ERUs
The Russian Ministry of Finance has noted that the VAT treatment of services generally depends on the place of their supply. Recently they issued Letter No. 03-07-08/4775 on February 20, 2013 regarding the VAT treatment of agency services supplied
See MoreRussia: Clarifications regarding the advance pricing agreements
The Ministry of Finance has released Letter 03-01-18/2676 on February 6, 2013 clarifying the procedure for concluding advance pricing agreements (APAs) for foreign transactions. According to article 105.20 of the Tax Code the Ministry of Finance
See MoreDraft list of commodities conditional to transfer pricing rules
Under the Russian transfer pricing (TP) rules in effect since 1 January 2012, import/export transactions with unrelated parties may be subject to the transfer pricing rules if such transactions involve global exchange-traded commodities. The
See MoreRussia: Amendments to Tax Code regarding corporate property tax
Russian Federal Law No. 202-FZ, issued on November 29, 2012, amended the Tax Code by introducing additional exemptions from corporate property tax. From January 1, 2013, the categories of assets not subject to corporate property tax include movable
See MoreIncome and Capital Tax Treaty between Argentina and Russia
The Income and Capital Tax Treaty (2001) between Argentina and Russia, which was signed on 10 October 2001, entered into force on 16 October 2012. The treaty is expected to be applied from 1 January 2013. It generally follows the OECD Model
See MoreDTA between Latvia and Russia entered into force
According to media reports, the double taxation agreement (DTA) between Latvia and Russia, signed in 2010, entered into force on November 6,
See MoreRussia: Polymetal Loses Transfer Pricing Dispute
On 1 August 2012 it was published that the Supreme Arbitration Court of Russia has recently ordered Polymetal International, a Russian gold and silver producer, to pay RUB883m in additional taxes, penalties and interest as part of a transfer pricing
See MoreRussia Lines Up Heavy Crude Export Tax Relief
On 9 March 2012 it was reported that the Russian government is considering the introduction of a significant new tax concession to make expensive extra-heavy crude extraction and refinement projects more viable, to boost the nation's export
See MoreRussia- Introduces new Transfer Pricing Rules
New Federal Law FZ-227 of 18 July 2011 which enacted comprehensive transfer pricing rules entered into force on 1 January 2012. According to the new Law, companies falling under the scope of transfer pricing rules will be obligated to disclose
See MoreAdvanced Pricing Agreement Guidelines published in Russia
On January 31 2012 it has been published that, the Russian Federal Tax Service published a letter No.ОА-4-13/85 “On Conclusion of Advanced Pricing Agreements for the tax purposes” dated 12 January 2012 on its official website. The letter is a
See MoreTax and Financial Agreements between Russia and Switzerland
A memorandum on bilateral cooperation between the two countries, Russia and Switzerland, has been signed on financial matters. It was reported on the occasion of the annual International Monetary Fund meeting held in Washington, on 28 September
See MoreAuthorities’ use of net-back approach in transfer pricing case has been overruled by the Russian Court
The Federal Arbitration Court of the Moscow Region rejected the Russian Tax Authorities’ attempt to adjust a taxpayer’s transfer pricing by applying the net-back approach. The net-back method are applied to oil production and operates by taking
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