Tax implications of updating the list of "offshore" jurisdictions with regard to transfer pricing

On 1 July 2023, Russian Ministry of Finance Order No. 86n "On Approving the List of States and Territories Providing a Preferential Tax Regime and (or) Providing No Disclosure and Provision of Information When Conducting Financial Transactions (Offshore Zones)" comes into force.

The updated List significantly expands the list of jurisdictions (which previously included mainly "non-transparent" territories with preferential business conditions), by including 49 new ones (which the Ministry of Finance classifies as unfriendly), and expands the range of potentially controlled transactions. In this regard, taxpayers who have entered into cross-border transactions may face increased transfer pricing obligations. Please, see the details in the pdf attached.

Our services

Tax & Legal

Integrated services for compliance with legal requirements