Mandatory Transfer Pricing Documentation – High Financial Risks

27.04.2026

Amendments are currently being made to Russian tax legislation, specifically in regard to transfer pricing (TP) rules.

Thus, starting from 2024, if the subject of foreign trade controlled transactions involves ‘raw materials’ from the List of the Ministry of Industry and Trade of the Russian Federation (non-ferrous and ferrous metals, precious stones, etc.), then mandatory TP documentation must be prepared on them and submitted to the Russian tax authorities.

These rules were initially intended to apply only to transactions involving natural resources. However, in practice, they also apply to non-resource companies that supplied goods with HS codes from the List of the Ministry of Industry and Trade of the Russian Federation (the Minpromtorg of the RF), even in small quantities.

Documentation on such transactions (along with the notification of controlled transactions) must be prepared by 20 May of the year following the reporting year. For controlled transactions for 2025, the deadline is 20.05.2026.

The fine for failure to submit TP documentation is RUB 500,000.

How we can help

We recommend reviewing your foreign trade contracts and determining whether your company has transactions involving goods with HS codes from the List of the Minpromtorg of the RF, as well as assessing the need to submit TP documentation. SCHNEIDER GROUP's tax team is ready to assist you in analyzing the impact of the new regulations on your business and preparing the appropriate documentation to avoid fines and penalties.