Svetlana Stroykova Introduced in 1999, the Russian transfer pricing legislation has not proven an efficient tool. The government officials believe a number of factors make the Russian transfer pricing rules "work improperly". In particular, officials cite the burden of proof of non – arm's length nature of prices applied by the taxpayers resting with the Russian tax authorities; the existence of the 20% safe harbour allowing the taxpayers to shift considerable profits offshore; the absence of penalties in case of a transfer pricing adjustment; and the lack of experience of the Russian tax authorities in understanding transfer pricing concepts as problems.
March 01 2007