Russia: local rules

Transfer pricing rules are in Section V.1 of Part One of the Tax Code (art. 105.1 to 105.25). Prices in deals between interdependent (related) persons are tested against market prices, and the tax service may add the income that was not received because of non-market terms (art. 105.3(1)). Persons are interdependent at more than 25% direct or indirect ownership, through control of the board or management, and on other grounds (art. 105.1). The tax service can check profit tax, personal income tax, mineral extraction tax, VAT and additional hydrocarbon income tax for controlled deals (art. 105.3(4)). Only deals that are controlled under art. 105.14 are tested. Those are deals between interdependent persons above the thresholds, offshore deals, chains with intermediaries that add nothing, and foreign trade in oil, metals, fertilizers and precious metals and stones.

Controlled deals must be reported in a notification by 20 May of the next year (art. 105.16(2)). Cross-border deals are controlled when income with one counterparty is above RUB 120m a year (art. 105.14(3)). Purely domestic deals are controlled only in listed cases, such as different profit tax rates or a tax exemption, and then above RUB 1bn. Transfer pricing documentation is not filed unless asked. The tax service may ask for it from 1 June of the next year, and it must be handed over within 30 days of receiving the request (art. 105.15(3)). Documentation for the listed commodity deals goes in with the notification (art. 105.15(8)). Groups also use the international group rules (Chapter 14.4-1): a notification of group participation, global documentation (master file), national documentation (local file) and a country report. These apply under a RUB 50bn group revenue test for a Russian parent.

Art. 105.7 lists five methods: comparable market prices, resale price, cost plus, comparable profitability (TNMM) and profit split. Comparable market prices is the priority method. The others are allowed when it cannot be used or does not give a sound answer, and a mix of methods is allowed. The tax service uses the methods when it tests prices, and the taxpayer may also adjust its own tax base to market levels (art. 105.3(3)). Advance pricing agreements are available under Chapter 14.6.

Not filing the controlled deals notification, or filing wrong information, costs RUB 100,000 (art. 129.4). Under art. 129.3, underpaid tax from non-market prices brings a fine of the unpaid tax, at least RUB 500,000, for most controlled deals. For the domestic deal cases in art. 105.14(2) the fine is 40% of the unpaid tax, at least RUB 30,000, and it falls away if documentation was handed over as required. A missing or wrong group participation notification costs RUB 500,000 (art. 129.9), and a missing or wrong country report costs RUB 1,000,000 (art. 129.10).

Russia has not adopted the OECD GloBE rules. It has no income inclusion rule, no qualified domestic minimum tax, no undertaxed profits rule and no GloBE Information Return. Instead, Federal Law No. 425-FZ of 28 November 2025 added art. 288.5 and art. 284(1.20) to the Tax Code from 1 January 2026. A Russian member of a foreign-parented group pays profit tax at 15% (5% federal, 10% regional) on its base when all of these hold: the parent is a foreign tax resident, the parent or an intermediate holding is resident in a country on the list of countries with OECD minimum tax rules, group revenue was above the ruble equivalent of EUR 750m in each of the two prior years, and the member's own tax burden ratio is above 0 and below 0.15. There is no separate return. The tax is worked out for the year in the normal annual profit tax return (due 25 March) and paid by 28 March, so the first time is the 2026 return, due 25 March 2027.

The profit tax return is due by 25 March after the calendar year (art. 289(4)), and the tax by 28 March (art. 287(1)). Under art. 6.1(7), a deadline that falls on a weekend or a non-working day moves to the next working day. Russia's tax year is the calendar year. Days off are moved each year by Government decree, and 31 December was a day off in 2024, 2025, 2026 and 2027. Sanctions rules in other countries may apply to dealings with Russian entities; check the rules that apply to you.