February 7, 2024 Client alerts, Tax practice, Transfer pricing

Transfer Pricing: Changes in 2024

Some significant changes in the regulation of transfer pricing[1] came into effect on January 1, 2024. In our opinion, there are two key objectives that they pursue:

One is to encourage taxpayers to take a more conservative approach to setting transfer prices by raising costs for businesses where transfer prices are found to be inconsistent with the arm’s length principle; and
The other is to ease the administration of transfer prices to for tax authorities, sometimes by increasing the administrative burden on businesses.

We will take a closer look at these changes below. To read the legal alert please click here.

[1] Federal Law No. 539-FZ of November 27, 2023 On Amendments to Parts I and II of the Russian Tax Code, Certain Legislative Acts of the Russian Federation, and the Invalidation of Certain Provisions of Legislative Acts of the Russian Federation