Russia Publishes Guidance on Independent Corresponding Adjustments for Controlled Transactions
The Russian Ministry of Finance recently published Letter No. 03-01-18/15939, which provides guidance for corresponding adjustments for controlled transactions. According to the letter, when a taxpayer is a party to a controlled transaction that is not at arm's length resulting in an adjustment to that taxpayer's tax base, a corresponding adjustment may be made by the other party to the transac…
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