The Russian Ministry of Finance recently published guidance letter 03-12-12/1/37761 concerning the transaction threshold for the determination of transactions as controlled for transfer pricing purposes in 2021 and 2022. In particular, the letter addresses transactions between unrelated parties that are deemed controlled under paragraph 1 of Article 105.14 of the Tax Code. This includes:
- Transactions for the sale (resale) of goods, the performance of works, or the provision of services made …