Transfer pricing
Analysis of intragroup transactions and transfer pricing documentation
Analysis of intragroup turnover and transactions to identify operations subject to transfer pricing rules. Review of transaction terms, prices and profitability, and determination of whether documentation is required.
Preparation of transfer pricing documentation in accordance with tax legislation, including national documentation, and of notifications of controlled transactions.
Synergy Audit supports controlled transactions under Section V.1 of the Tax Code of the Russian Federation
Controlled transactions
Identifying transactions treated as controlled (Article 105.14 of the Tax Code of the Russian Federation), including, from 2026, transactions with parties from states with a corporate income tax rate of 15% or lower, analysis of related-party relationships
Notifications
Preparation of notifications of controlled transactions, due by 20 May of the year following the calendar year in which the transactions were carried out (Article 105.16)
Documentation
Documentation for controlled transactions (Article 105.15) with a functional analysis and support for arm's length prices and profitability
Multinational groups
Notification of participation in a multinational group, local file, master file and country-by-country report (Chapter 14.4-1)
Adjustments
Voluntary adjustment of the tax base (Paragraph 6 of Article 105.3) and corresponding adjustments (Article 105.18)
Advance pricing agreements
Preparation and support of an advance pricing agreement with the Federal Tax Service (Chapter 14.6)
The analysis applies the methods of Chapter 14.3 of the Tax Code of the Russian Federation to data on comparable companies and transactions. The result is notifications and documentation that support arm's length prices and reduce the risk of additional tax assessments.