The Russian Ministry of Finance recently published Guidance Letter No. 03-12-11/1/126454 of 27 December 2023 on the application of Order No. 86n of 5 June 2023 in relation to the recognition of transactions as controlled for transfer pricing purposes. As previously reported, Order No. 86n approved a new list of states and territories that provide a preferential tax regime and/or do not provide for the disclosure and provision of information on financial transactions, which was significantly e…