Transfer-pricing documentation is only required for certain transactions — but the notification and local-file obligations above the thresholds are real, and missing them is a penalty. Whether your intercompany flows cross those thresholds is the question.
Your related-party transactions are controlled and cross the value thresholds — then the notification and local file are obligations, not options.
Your transactions fall below the thresholds or outside the controlled definition — worth confirming rather than assuming either way.
If your Russian entity transacts with related companies abroad, transfer pricing rules apply — related-party transactions must be priced at arm's length, and above certain thresholds you must notify the authorities and hold documentation. This guide explains when the rules bite and what a defensible file looks like.
Transactions between related parties — and certain transactions treated as controlled — fall within the rules when they exceed statutory value thresholds. Cross-border intra-group sales, services, financing and royalties are the usual candidates. The first task is identifying which of your flows are controlled.
Controlled transactions must be priced as they would be between independent parties. Demonstrating this requires choosing an appropriate pricing method and benchmarking your prices against comparable market data. This analysis is the heart of the documentation.
Above the thresholds, two obligations arise: a notification of controlled transactions filed annually, and transfer-pricing documentation (a local file) that supports your pricing. For groups, the local file should align with the group master file so the story is consistent across jurisdictions.
Pick your situation — we'll tell you where you stand:
The obligations are threshold-based, so not every intra-group transaction triggers a full file — but misjudging the threshold is risky. Penalties for pricing violations can reach a significant percentage of the underpaid tax, and the documentation is the first thing the Federal Tax Service requests in a review.
A strong file identifies the controlled transactions, selects and justifies the pricing method, benchmarks against current comparables, and is kept up to date year on year. We prepare the notification and local file aligned to your group's approach, so an FTS review meets a documented, consistent position rather than a gap.
When controlled related-party transactions exceed statutory value thresholds. Above them, you must file an annual notification of controlled transactions and hold a local file supporting arm’s-length pricing.
Penalties can reach a significant percentage of the underpaid tax, and the documentation is the first thing the Federal Tax Service asks for in a review. A defensible local file is the main protection.
Yes. Aligning the Russian local file with the group master file keeps your pricing story consistent across jurisdictions and defensible in an audit.
This explains when TP documentation is actually required — which related-party transactions are controlled, and the notification and local-file obligations above the thresholds. Your question is whether your intercompany flows cross those thresholds, and whether you owe a filing you haven't made.
Related-party transactions with Russia? Worth confirming whether you've crossed a documentation threshold before the FTS asks.
Practical support for international business in Russia.