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 transaction.
In order for the other party to make a corresponding adjustment, the taxpayer making the ini…