The Russian Federal Tax Service (FTS) recently published Guidance Letter No. 03-01-18/73021, which clarifies advance pricing agreement (APA) application procedures. According to the letter, only Russian legal entities treated as large taxpayers may enter into APAs with the FTS (criteria for determination as large vary at regional and federal level). In order to apply for an APA, a petition must be submitted to FTS along with the following documentation:
- A draft APA;
- Details of the controlled…