transfer pricing reporting and documentation in 2015 russia

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Page 1: Transfer pricing reporting and documentation in 2015 Russia

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Accountor St. PetersburgShpalernaya Ul. 54191015 St. Petersburg+7 812 325 82 [email protected]

Timo SivonenExecutive Director+7 981 720 60 [email protected]

Accountor MoscowSadovnicheskaya nab. 79115035 Moscow+7 495 788 00 [email protected]

Samuli PesuDeputy CEO+7 926 710 [email protected]

Transfer pricing reporting and documentation in 2015

We would like to remind you about the most important questions regarding Russian transfer pricing legislation for the year 2015 and the associated responsibilities of taxpayers.

The related documentation listed below needs the time and involvement of experts. We would recommend that you start your preparations early; this will help you to decrease your tax risks. Thank you in advance for your prompt response.

1. Transfer pricing calendar 2015 and documents requested for statutory control:

20.5.2015 Deadline for tax declaration about controlled transactions for the year 2014

1.6.2015 From this date, state authorities can check the controlled transaction prices for the year 2014. The taxpayer should prepare documentation to justify the market level of prices in controlled transactions, the so-called transfer pricing documentation for the year 2014

31.12.2015 Last day an action can be instigated to check the controlled transaction prices for the year 2013. The transfer pricing documentation for the year should be available

Please, pay attention to the following points:• Year 2013: prices can be checked by the authorities if the cumulative volume of controlled transactions with

related non-residents for the year is more than 80 mln. rub. • Year 2014: all controlled transactions with non-residents can be checked by the authorities. There is no

limitation anymore: this was only applied during the transitional period, 2012-2013.

2. Penalties

If the tax checking reveals discrepancies between the prices of the controlled transaction and the market price level, which leads to an underestimation of taxes, the tax authorities may apply for a tax calculation of the market prices, and impose a penalty. For the transitional period 2012-2013, there will be no penalties, only the extra tax should be paid. From 2014 – a penalty will be charged equal to an additional 20% of the unpaid tax, and from 2017 the penalty will be 40% of the unpaid tax.

However, the taxpayer can be exempted from the penalty when they provide tax checking with the transfer pricing documentation (Tax Code art.1292).

We would be glad to support you in 1) the preparation of the transfer pricing documentation and 2) transfer pricing declaration for year 2014.

For more information, please contact:

2015_04_10 News

Samuli PesuDeputy CEOAccountor RussiaMobile: +7 926 710 4361 Office: +7 495 788 00 05 [email protected]

Daniil BerlizovSenior Business Development ManagerAccountor Russia Mobile: +7 916 539 68 66 Office:+7 495 788 00 05 (242)[email protected]

Page 2: Transfer pricing reporting and documentation in 2015 Russia

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Accountor St. PetersburgShpalernaya Ul. 54191015 St. Petersburg+7 812 325 82 [email protected]

Timo SivonenExecutive Director+7 981 720 60 [email protected]

Accountor MoscowSadovnicheskaya nab. 79115035 Moscow+7 495 788 00 [email protected]

Samuli PesuDeputy CEO+7 926 710 [email protected]