Russia Transfer Pricing Reforms from 2024

Russia has published Law No. 539-FZ of 27 November 2023 in the Official Gazette, which introduces several amendments to the country's transfer pricing regime. Some of the main changes are summarized as follows:

Secondary Adjustments Treated as Deemed Dividends for Non-Residents

New provisions on secondary transfer pricing adjustments are introduced, providing that where the price for a related party transaction involving a non-resident differs from the market (arm's length) price, and th…