Russia's new transfer pricing rules usher in a qualitatively new outlook in how the Russian tax authorities will consider intercompany transactions for tax purposes. Although some aspects resemble OECD principles, there are also significant deviations. Svetlana Stroykova, Ilarion Lemetyuynen, Adam Kosmala and Andrew Joshi of PwC provide an overview of the recent changes.
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The new guidance is not meant to reflect a substantial change to UK law, but the requirement that tax advice is ‘likely to be correct’ imposes unrealistic expectations
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