On 17 March 2017 the Ministry of Finance of Russia (MoF) posted a draft order on the procedure for conclusion of bilateral advance pricing agreements (APAs) with the authorised bodies of foreign states. This draft order fills in a legal gap in Russian administration of transfer pricing rules and treaty obligations with foreign states. Although conclusion of APAs is generally provided for in the Russian Tax Code (specifically by item 2 of Article 105.20 of the Russian Tax Code) for major taxpayers since 2012, it is only through this draft order that the procedure for conclusion of bilateral APAs has been established.
Under the draft order, it has been clarified that taxpayers will be able to request for the conclusion of bilateral APAs on transfer pricing matter with states that have effective double tax treaties with the Russian Federation. In fact, APAs can be concluded by Russia with one or more competent authorities of foreign states at the same time i.e. on a multilateral basis.
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