The threshold for recognizing transactions as controlled was increased in 2022

18.04.2022

From March 26, 2022, the rules for recognizing transactions as controlled transactions have been clarified:

  • the threshold for recognizing transactions as controlled was increased from 60 million rubles. up to 120 million rubles (the change is introduced on an indefinite basis),
  • transactions, income or expenses on which are recognized in the period from January 1, 2022 to December 31, 2024, regardless of the date of conclusion of the relevant agreement, are not subject to the provision that the transaction is recognized as controlled, if at least one of the parties to the transaction applies during the tax period, an investment tax deduction for income tax (clause 9, clause 2, article 105.14 of the Tax Code of the Russian Federation);
  • the penalty established by paragraph 1 of Article 129.3 of the Tax Code of the Russian Federation (for non-payment or incomplete payment of tax amounts as a result of the application in controlled transactions of commercial or financial conditions that are not comparable with the conditions of transactions between persons who are not related) is not applied to controlled transactions, income or expenses for which are recognized in the period from January 1, 2022 to December 31, 2023 inclusive, regardless of the date of conclusion of the relevant agreement.

Here you can learn more about Transfer pricing in Russia.

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