Advance Pricing Arrangements under the new Russian Transfer Pricing Law

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Advance Pricing Arrangements under the new Russian Transfer Pricing Law

 

Following the introduction of the new transfer pricing law from 1 January 2012, the Russian Federal Tax Service (hereinafter, “FTS”) started to issue clarifications and comments on application of provisions of this law.

Among of the first clarifications is a Letter2 explaining the procedure of concluding, executing and terminating an Advance Pricing Arrangement (hereinafter, “APA”) between a taxpayer and the tax authorities.

The key provisions of this Letter regarding the conclusion of an APA are summarised

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