Tax implications of the new transfer pricing rules from 2024

An increase in the number of offshore jurisdictions in 2023 and an automatic reduction in theamount of information provided for the purposes of tax control over transfer prices for cross-border transactions led to the needfor changes to the rules of tax regulation of transfer pricing and tax control over prices intransactions between interdependent persons established in the Russian Federation since 2012. The articleanalyzes the tax consequences of the introduction of new transfer pricing rules from 2024, aimed at curbingthe possibility of dilution of the tax base and the movement of income from foreign trade operations from theRussian Federation. The assessment ofprobudget and incentive measures of tax policy in relation to the newtransfer pricing rules has been carried out. The conclusions on the tightening of tax control over prices for taxpurposes on cross-border transactions are substantiated, which requires companies to review pricing approaches in order to avoid tax consequences.