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New transfer pricing developments: secondary filing required of Country-by-Country reports with the Russian tax authorities

Review by Kept

On 13 November 2023 a draft Order of the Federal Tax Service of Russia “On Approving the List of States (Territories) that Commit Systematic Violations of Obligations on the Automatic Exchange of Country-by-Country Reports” was made available on the Federal Portal of Draft Laws and Regulations. The List comprises 21 foreign states which are predominantly ‘unfriendly’ EU-member states and Japan, and also the Bermuda territory.

The Order may have come about due to difficulties faced by the FTS of Russia in obtaining Country-by-Country reports from foreign jurisdictions as part of the automatic exchange of information. These challenges flow organically from public statements made by a number of countries on renouncing the exchange of tax information with Russia.

Read a review by Kept for details.

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