Russia Clarifies Independent Corresponding Adjustments for Controlled Transactions Involving Non-Resident Related Parties

The Russian Ministry of Finance recently published Letter No. 03-01-18/28673, which provides guidance for corresponding adjustments for controlled transactions involving non-resident related parties. According to the letter, transactions between resident and non-resident related parties are deemed controlled regardless of the amount of income. When a taxpayer is a party to a controlled transaction that is not at arm's length resulting in an adjustment to the taxpayer's tax base, the counter p…