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Clarification on Russian Transfer Pricing Rules for Domestic Transactions

|Approved Changes|Russia
Russia

Through Letter No 03-01-18/2080, the Russian Ministry of Finance has provided clarification on the matter of when domestic transactions are deemed to be a controlled transaction for transfer pricing purposes.

Under Article 105.16 of Russia's Tax Code, if one taxpayer in a domestic transaction is taxed under the Uniform Tax on Imputed Income regime and the other party is not, it will be deemed to b…

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