Customs valuation for related-party imports: documentation set to survive audits

When a Russian importer buys from its foreign shareholder, HQ, or sister company, customs officers look at the price more closely. The relationship itself is not a violation, but it always raises the same question: would an independent buyer pay the same amount?

If the Federal Customs Service (FCS) is not convinced, it may uplift the customs value, assess extra duties and VAT, and impose penalties.
A structured documentation set is your main defence. The stronger your file, the less room there is for speculative adjustments during a customs audit.

When related-party imports attract special attention

Related-party pricing is more likely to be challenged when at least one of the following is true:

the Russian entity shows low or negative margin on imported goods;
the declared customs value looks lower than comparable imports by other buyers;
there are regular rebates, year-end bonuses, or free-of-charge deliveries;
the Russian entity bears significant risks but earns a very modest reward;
there are additional payments in the group (royalties, management or marketing fees) that may be linked to imported goods.

None of these factors is fatal on its own, but together they create a profile that invites questions from FCS.

“

For related-party imports, the key question for Russian customs is simple: would an independent buyer accept the same price and terms? If you cannot prove that with documents, you should expect challenges to your customs value

Julia Vernikovskaya, Financial Director at Outsourcing Solutions.

Documentation set for related-party imports

A robust file for customs valuation normally includes several layers.

1. Intercompany contract and pricing mechanics
The agreement should clearly describe the product scope, Incoterms, payment terms and pricing formula. If discounts, bonuses or volume rebates apply, they should be reflected in the contract or in written policies, not left to informal arrangements.

2. Transfer pricing documentation and functional analysis
Customs officers will look at how profits are allocated within the group. Transfer pricing reports, functional analysis and group policies should explain which entity owns IP, carries inventory risk, manages key decisions and what level of margin is expected for the Russian entity. The story in TP documentation and the story told to customs must be consistent.

3. Market-level support for prices
Benchmarking studies, internal comparisons with independent customers, external databases or industry sources can help demonstrate that your prices are broadly in line with market conditions. The goal is not perfect precision, but a reasonable justification of the overall price level.

4. Operational documents
Invoices, specifications, price lists and internal approvals should confirm that the pricing model from the contract is actually applied in day-to-day operations. Frequent manual corrections, unexplained free-of-charge deliveries or undocumented discounts create doubts and invite adjustments.

5. Additional intra-group payments
Royalties, service fees and other intra-group charges are a sensitive area. Agreements and internal memos should clearly describe what the Russian entity receives, how the fee is calculated, and whether it relates to imported goods. This helps to determine if such payments should be added to the customs value.

6. Internal summary for audits
A short internal memo mapping flows of goods, related suppliers, contracts and pricing models often saves time during an audit. It allows local teams to respond quickly and consistently when customs requests information.

Preparing for a customs audit

Before FCS sends formal questions, it is worth running a quick internal review:

map your related-party supply chains and contracts;
check that customs, tax and transfer pricing positions are aligned;
identify high-risk product groups or transactions and strengthen their documentation;
prepare standard response packages for typical customs information requests.

For groups that rely on intra-group imports into Russia, customs valuation is not a one-off project but an ongoing compliance area. A well-prepared documentation set turns related-party imports from a permanent source of uncertainty into a manageable part of doing business in the Russian market.

Need to review your related-party import pricing in Russia?
If your group relies on intra-company supplies to the Russian market, we can help review your customs valuation approach, align it with transfer pricing, and prepare a documentation set that is ready for audits. Contact us at Outsourcing Solutions to discuss a tailored customs valuation review for your Russian operations.

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