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 be a controlled transaction and subject to the arms length pricing requirement. In addition, the lett…