Transfer Pricing

Schekin & Partners has diverse experience applying the new transfer pricing rules, including drafting pricing agreements with the Federal Tax Service of Russia and developing transfer pricing reports to demonstrate that our clients’ actual prices are in line with fair market prices.

Our professionals have also handled a number of court cases regarding fair market prices under Article 40 of the Russian Tax Code, building a solid foundation to deliver expert assistance in the field of transfer pricing.

We focus on the practical application of transfer pricing methods and proactively develop defense strategies for potential disputes with the tax authority.

When we develop or review a transfer pricing report, we focus on making sure that it will serve as well-structured and well-founded evidence in potential litigation.

Examples of our work:

  • We assisted a major oil company in drafting and negotiating a pricing agreement with the Federal Tax Service of Russia.
  • We performed comprehensive analyses and developed transfer pricing reports for transactions involving lease and finance lease, imports of goods by distributors, domestic and export sales of crude oil and petroleum products, and imports of materials for processing.
  • We performed transfer pricing analysis for borrowings by a major Russian oil company.
  • We performed economic analysis of costs and defined approaches to calculating actual margins in controlled transactions at a large chain retailer.
  • We advised an oil group on controlled transactions and methods for demonstrating that actual prices of goods/work/services are at arm’s length.
  • We advised a major oil company on the pricing methodology developed by professional economists in advance of signing a pricing agreement.
  • We advised a leading oil company on the transfer pricing compliance of its pricing policy for guarantee fees.
  • We helped a client identify tax risks associated with transactions subject to pricing control under section V.I of the Russian Tax Code. In particular, we helped identify the risks of the current pricing approach and developed recommendations for minimizing such risks.