Transfer Pricing

The lawyers at Forte Tax & Law have extensive experience in assisting clients with international tax planning, including transfer pricing which is one of the key practices of the firm. Over the past few years, we have been involved in numerous transfer pricing assignments which were completed for companies operating in various industries in Russia.

• Advising legal entities on transfer pricing issues and analyzing risks
• Identifying controlled transactions
• Conducting economic analyses and comparability analyses (benchmark)
• Preparing transfer pricing documentation
• Assisting in preparing controlled transaction reports
• Assisting foreign companies in adapting transfer pricing policies to the requirements of Russian law
• Assisting with the settlement of disputes arising from tax audits of pricing issues for tax purposes

• Developing the transfer pricing policy for the Russian subsidiary of one of the largest Scandinavian flooring manufacturers to justify the prices applied by the company in intragroup transactions and advising on issues of transfer pricing. The group’s market consists of Finland, the Baltic and CIS countries, Russia, Scandinavia, and the group is also involved in international projects. To develop the transfer pricing policy, we conducted a functional analysis of transactions with the group companies, we analyzed the situation in the industry and identified the specific advantages offered by the company’s products, which allowed justifying the prices applied by the company
• Advising one of the largest Scandinavian suppliers of construction materials and equipment operating in Finland, Sweden, Norway, Poland, Russia, the Baltic countries and Kazakhstan on how to adapt their transfer pricing policy to the requirements of Russian law
• Preparing a transfer pricing policy and providing related advice to a foreign company specializing in the wholesale of bearings used as components by various machine-building enterprises in Russia
• Preparing recommendations for a major European manufacturer of multilayer film used in food and medical industries to bring transfer pricing documentation in line with Russian requirements
• Assisting a major Scandinavian company specializing in the development, manufacture and marketing of electrical systems and supplies for the distribution of electrical power as well as electrical applications in complying with new transfer pricing rules, including preparing transfer pricing documentation and assisting with reports on controlled transactions