According to the Draft Law No.79859-6, sent for the second reading in the State Duma, intra-group loan agreements will be subject to transfer pricing control as from 1 January 2013. Intra-group loan agreements that are concluded before 1 January 2012 will not be subject to those rules. However, intra-group loan agreements that were amended in the tax year 2012 would be affected by the new transfer…