Transfer pricing

Transfer pricing is one of the most important tax issues facing not only large international organisations, but also any company that manages cross-border operations. In Russia, as in many other countries, transfer pricing legislation is constantly changing.

Transfer pricing

Over the past 7 years, Marillion team has successfully completed more than 300 TP projects for international groups of companies in various industries, including manufacturing sector, consumer goods industry, pharmaceuticals, food and beverages, etc.

 Marillion Transfer Pricing services at a glance

Our team assists clients with the following issues:

  • Carrying out diagnostics of TP risks;
  • Developing internal policies on intragroup transaction pricing;
  • Introducing appropriate information flows required for TP compliance;
  • Preparing TP Documentation and TP Notification;
  • Advising foreign companies entering the Russian market on the existing TP regulations, so that group TP policies and approaches are adjusted accordingly from the beginning to reduce potential TP risks.


In Russia, according to the TP rules entered into force in 2012, a company must:

  1. Submit a Notification on Controlled Transactions to the tax authorities by 20 May of the year following the reporting year

Notification should contain general information on each transaction (information on the parties of the transaction, subject of the transaction, information on the agreement, transaction fees, etc.), as well as background information on the TP method and the sources of information used by the company.

  1. Within 30 days starting after the date of the tax authorities' request one must submit transfer pricing documentation to the tax authorities

If a taxpayer fails to submit the requested Documentation within the established period (due dates), additional tax adjustment and a 40% penalty on the amount of unpaid tax may be applied.

The submission of the Documentation shifts the burden of proof to the tax authorities.


Federal Law of 27.11.2017 № 340-FZ (hereinafter - the "Law") introduced the so-called "three-tier" TP documentation. Starting from the tax period of 2017, taxpayers who are members of international groups of companies (IGC), the amount of income (revenue) of which exceeds the criterion established by the legislation of the state, the tax resident of which is the parent company of IGC (for most European countries - 750 million euros), have to submit a Notification of participation in IGC to the tax authority, as well as, at the request of the Russian tax authority, TP documentation, consisting of three tiers:

  1. Local File;
  2. Master File;
  3. Country-by-country report, CbCR.

If the local documentation (Local File) is identical in its essence / structure to the TP documentation, which was submitted under the provisions that were in force before the entry into force of the Law, the global documentation (Master File) contains a number of indicators for the Group as a whole, so it should be prepared on a centralized basis (at the Group level).

The global documentation is submitted within three months starting after the date of receipt of the relevant claim from the tax authorities. In this case, the global documentation (Master File) can be requested from the taxpayer not earlier than 12 months and not later than 36 months starting after the end date of the reporting period specified in the requirement.

Failure to submit the Master File by the taxpayer within the established period will result in a fine of 100,000 rubles. At the same time, a transitional period is established: the penalty is not applied to reporting periods starting from 2017, 2018 and 2019.

The third tier of documentation (process) is the so-called country-by-country report (CbCR). However, the country-by-country report for the whole IGC is submitted to the tax authorities only by the parent company of IGC or a specially authorized member of the IGC. The Russian company, in turn, will have to provide the parent company with the necessary data for the formation of the country-by-country report.

The country-by-country report shall be submitted no later than 12 months starting after the end of the reporting period.

If the country report is submitted at the request of the tax authority, the tax authority shall specify the due dates for submission of the country-by-country report in such a request; such due dates shall not be less than three months starting after the date of the request receipt.

Illegal failure to submit the country-by-country report within the established due dates or submission of the country-by-country report containing inaccurate information shall result in a fine in the amount of 100,000 rubles.

At the same time, a transitional period shall be established: the penalty shall not apply to the reporting periods starting from 2017, 2018 and 2019.

Marillion recommendations:

  • By the time of preparation of the Notification, the company should be prepared to provide detailed information on the pricing mechanism for each controlled transaction included in the Notification.
  • 30 days is clearly not enough to prepare the Documentation, so it is recommended to prepare the Documentation in advance.

Marillion TP expertise

According to International Tax Review, Marillion is recognized as one of the leading Tier 2 companies in Russia in the World Transfer Pricing Ranking.

We use various information databases to obtain comparable data: SPARK, RUSLANA, AMADEUS, ORBIS, BLOOMBERG, Royaltystat, and others.

We offer quality and individual solutions that suit your budget.

What are the additional benefits of preparing Transfer Pricing documentation?

Besides elimination of compliance risks, proper transfer pricing solutions can provide various benefits, such as:

  • A lower effective tax rate;
  • Improved intragroup cash flows;
  • Mitigation or even elimination of tax risks related to intragroup flows.