Documentation on Transfer Pricing and Controlled Transactions

2026 has only just begun, but it is already time to consider preparing notifications of controlled transactions and transfer pricing documentation for 2025.

Reporting deadlines tend to arrive rather quickly, and the volume and complexity of transfer pricing workload has increased significantly.

To recap, here are the key criteria that apply to controlled transactions:

• Transactions over 120 million rubles per year with overseas interdependent parties;
• Transactions over 120 million rubles per calendar year with parties registered in off-shore jurisdictions. The list of such countries has been significantly expanded (now including, in particular, the EU, the US, the UK, the UAE, and others);
• Transactions between Russian interdependent parties exceeding 1 billion rubles per year (pursuant to additional conditions established by the Tax Code of the Russian Federation).

We would like to draw your attention to the tightening of sanctions. The penalty for failure to submit a notification on controlled transactions is 100,000 rubles. In 2024, another penalty was introduced for failure to submit transfer pricing documentation — 500,000 rubles.

We are already setting up the schedule of transfer pricing projects for 2026 and are ready to plan our joint work in advance in order to:

• Analyze your transactions to determine whether they qualify as controlled and whether notification is required;
• Help you to select the correct method for transfer pricing and justify that choice, as well as identify sources of information for market prices;
• Prepare and submit a report on controlled transactions in the applicable form;
• Prepare turnkey transfer pricing documentation, taking into account the latest changes in legislation and tax control practices.
• Support you in your communications with tax authorities, including in case of disputes.

Bellerage team have extensive experience in transfer pricing, as well as accounting and tax accounting, including international taxation aspects.

This proactive approach allows you to spread the workload evenly, reduce the risk of penalties and additional charges, and ensure predictability of the tax burden for your business.
If you'd like to discuss your controlled transactions, evaluate risks, or reserve a slot advance, please let us know—we are happy to assist.