“Three-tier” transfer pricing documentation e-formats approved in Russia

The Russian Federal Tax Service has recently approved the formats for filing three-tier transfer pricing documentation – specifically, the filing of notifications of participation in multinational groups of companies* (“MGCs”) and country-by-country reports* (“CbCRs”).

Both MGCs and CbCRs must be filed electronically in these new formats.

The first reporting deadline for filing notifications of participation in MGCs is 31 August 2018. These notifications must be filed by all Russian taxpayers who are part of an MGC.

CbCRs must be filed by Russian taxpayers, depending on their role in an MGC, by 31 December 2018 or at the request of the Federal Tax Service.

Starting from 2018, Russian taxpayers who are part of an MGC face new reporting requirements established by Federal Law 340-FZ*. Details on these new requirements can be found in our previous Tax Alert.

To avoid missing deadlines, it is highly recommended that MGC members who are Russian taxpayers do the following:

• assess whether or not they are obliged to prepare and file the new transfer pricing reporting forms; and
• analyse the format and content of the new reporting forms, and start gathering the necessary information for the 2017 reporting period.

* In Russian