Russia - Guidance on Controlled Transactions Aggregation
- S. Stroykova; O. Manankova
- International Transfer Pricing Journal, 2014 (Volume 21), No 1
- 15 January 2014
Since April 2013, the Ministry of Finance has issued several Letters that clarify certain transfer pricing provisions of the Russian Tax Code and the taxpayer’s right to aggregate controlled transactions into groups for purposes of preparing the notification on controllable transactions and transfer pricing documentation.