On 3 August 2018, the President of the Russian Federation signed Law No. 302-FZ “Concerning Amendments to Parts One and Two of the Tax Code of the Russian Federation”
Under the new Law domestic transactions will only be subject to transfer pricing rules where the contracting parties are domestic entities that are subject to different tax rates or special tax regimes and where the revenue from those transactions exceeds 1 billion rubles per year.
Specifically, only transactions between Domestic Entities that meet any of the conditions below will be subject to the Law:
The new law also provides a unified revenue threshold of 60 million rubles for cross-border transactions to be classified as controlled for transfer pricing purposes.
The new law will be effective for transactions that take place after 1 January 2019, irrespective of when the relevant contract was concluded.
The law also contains amendments that are not directly related to transfer pricing, including: