The Start of the 2026 Transfer Pricing (“TP”) reporting season

If your company engages in controlled transactions and is part of a multinational group of companies (the “MGC” – Russian equivalent of MNE), you are required to comply with the annual cycle of TP obligations, each stage of which demands timely and thorough preparation.

As the 2026 TP reporting season approaches, we would like to remind you of the key stages and deadlines that will require your attention in the coming weeks.

Notification of controlled transactions

The Notification of controlled transactions (the “TP Notification”) for transactions carried out in 2025 must be submitted using the prescribed form by 20 May 2026.

For transactions involving specific groups of goods (primarily exchange-traded goods), documentation* demonstrating that the prices comply with market prices must be submitted together with the TP Notification.

TP documentation

From 1 June 2026, the Federal Tax Service of Russia may request documentation confirming the arm’s length nature of prices applied in controlled transactions carried out in 2025 (TP documentation). Please note that TP documentation may also be requested as part of a pre-audit analysis.

In practice, this leaves very limited time for preparation, so it is advisable to start preparing the documentation well in advance, as regularly emphasized by the tax authorities.

Please note that, from 2024, the requirements regarding the content of TP documentation have been significantly expanded. In addition to the standard elements (justification of arm’s length pricing, functional analysis, and benchmarking), the documentation must include:

• a description of the TP methods applied, and the sources of information used;
• for foreign counterparties, information on financial indicators, headcount, assets, as well as registration details and supporting documentation.

Three-tier reporting

For participants in an MGC, TP control and exchange obligations are not limited to notifications and transaction documentation. The scope of compliance requirements may also include:

• a Country-by-Country Report (taking into account restrictions on the exchange of information, which may create an additional compliance burden for the Russian party);
• Master File adapted to Russian requirements (upon request of the tax authority);
• Local File;
• a Notification of Participation in the MGC (submitted annually using the prescribed form);
• Information from consolidated financial statements (where the relevant criteria are met).

Liability and monitoring

Please note that, for transactions carried out in 2025, stricter liability measures apply for breaches of TP legislation, including:

• a fine of RUB 500,000 for failure to provide TP documentation or for providing incomplete documentation;
• adjustment of prices to the median value, which may significantly increase the tax burden;
• for cross-border transactions, the application of “secondary TP adjustment” rules, including requalification into dividends and the imposition of withholding tax.

How we can we help

We would be pleased to analyse your controlled transactions, provide practical recommendations for mitigating existing risks, and prepare any required reporting forms on a turnkey basis.

Our team includes recognised TP experts with extensive practical experience in documenting complex transactions and addressing related regulatory matters.

* In Russian