TP documentation, benchmarking and FTS audit defence.
Transfer pricing documentation and defence for international groups with Russian entities — local file, controlled-transaction analysis and benchmarking prepared to survive an FTS review, where the penalty for violations is 40% of the underpaid tax.
Transfer pricing is one of the highest-exposure areas for an international group operating in Russia, because the penalty for violations is 40% of the underpaid tax, subject to a statutory minimum. The risk is not the concept but the documentation: the FTS expects a local file that identifies controlled transactions, explains the pricing method and supports it with benchmarking against arm’s-length ranges.
We prepare the annual documentation end to end — identifying which intra-group transactions are controlled, selecting and applying the appropriate method, running benchmarking studies and coordinating with the group master file. We also handle the transfer pricing notification, so the filing and the documentation tell one consistent story.
Where a review is already underway, we defend the position: responding to FTS requests within the statutory deadline, drafting objections to the audit act and representing the company through pre-trial appeal. The goal is documentation robust enough that most disputes are closed before they escalate.
We identify controlled transactions, select and apply the appropriate pricing method and prepare a local file that documents the arm’s-length position clearly enough to survive an FTS review.
Comparable searches and margin analysis for intra-group goods, services and financing, supporting the method chosen in the local file.
Annual notification of controlled transactions, prepared consistently with the documentation so filing and file tell one story.
We respond to information requests within the statutory deadline, draft objections to the audit act and represent the position through pre-trial appeal. The penalty for TP violations is 40% of the underpaid tax, subject to a statutory minimum.
Your Russian entity has controlled transactions with related parties abroad that exceed the notification threshold.
An FTS transfer pricing review is expected and the local file must be defensible.
Intra-group services, financing or goods flows need benchmarking against arm’s-length ranges.
Recognise your situation? Transfer pricing documentation is cheap to prepare and expensive to reconstruct.
30 minutes with a senior adviser — or send a note instead, if you would rather write.
Prepared the local file and benchmarking for intra-group transactions across three jurisdictions, identifying controlled transactions and documenting the arm’s-length position ahead of the TP notification deadline — closing the FTS exposure before any review began.
Identify controlled transactions above the statutory thresholds.
Study arm’s-length ranges and select the pricing method.
Prepare documentation aligned to the group master file.
File the notification and respond to any FTS review.
Where controlled transactions exceed the statutory thresholds; we assess your position and prepare the notification and local file.
The penalty is 40% of the underpaid tax, subject to a statutory minimum — which is why defensible documentation matters.
Yes — we respond to FTS requests, draft objections to the audit act and represent the position through pre-trial appeal.
By email, WhatsApp, Telegram or WeChat. Describe your situation briefly — we don’t need everything upfront.
A named adviser replies — not a generic inbox. We confirm whether we can help and propose a call if needed.
We ask about your situation, Russian entity structure and what you need. No charge. In English, Russian or Chinese.
Clear scope, fee and timeline. We start on receipt of the signed letter. No retainer lock-in on project work.
Practical support for international business in Russia.