How to check the correctness of pricing for tax purposes. what date to indicate in the notification of controlled transactions on line 150 "Date of the transaction ..." section 1B. The cost of the goods was changed after the sale - read the article.
Question: Is it necessary to submit a report on controlled transactions if in 2016 if for such transactions in 2016. there were only payments. In fact, the transactions are reflected in the report for 2015.
Answer: If controlled transactions took place in 2015 and the 2015 notice was filed, you do not have to file the 2016 notice. The fact of payment will not affect the date of the transaction.
Rationale
How to check the correctness of pricing for tax purposes
Notice of controlled transactions
Every year, organizations (individuals) must notify the tax inspectorates about completed controlled transactions. In 2017 (no later than May 22) it is necessary to inform the inspections about controlled transactionscompleted in 2016. Determining the range of transactions that need to be notified tax office according to the results of 2016, be guided by the list provided in the Tax Code of the Russian Federation, without any restrictions. This is stated in the letter of the Federal Tax Service of Russia dated March 11, 2015 No. ED-4-13 / 7083.
An example of filing a notice of a controlled transaction made in 2016
In March 2016, Alfa LLC sold a real estate property to its subsidiary LLC Trade Firm Germes with total area 2000 sq. m at a price of 32,000 rubles/sq. m. Cost square meter determined and agreed in the contract on the basis of prices for similar objects published in open sources of information.
Alpha is using common system taxation. Hermes applies simplified taxation and pays single tax from income. There were no other transactions between Hermes and Alfa in 2016.
Having determined the income from the transaction in the amount of 64,000,000 rubles. (excluding VAT), Alfa's accountant found that this transaction falls under the definition of a controlled one. In doing so, he took into account the following circumstances:
- the parties to the transaction are interdependent ();
- the subsidiary is exempt from paying income tax (subclause 4, clause 2, article 105.14 and clause 2, article 346.11 of the Tax Code of the Russian Federation);
- the annual income from the transaction exceeded limit value 60 million rubles (paragraph 1 clause 3 and clause 9 article 105.14 of the Tax Code of the Russian Federation).
The parties must notify the tax inspectorates of a controlled transaction made in 2016 no later than May 22, 2017 (clause 7, article 6.1, clause 2, article 105.16 of the Tax Code of the Russian Federation). Therefore, by May 22, 2017, the accountants of both organizations prepared and submitted notifications of the real estate purchase and sale transaction to their tax inspectorates. When preparing documents, they were guided by the Procedure, approved by order of the Federal Tax Service of Russia dated July 27, 2012 No. MMV-7-13 / 524.
Notification of a controlled transaction must be submitted by each of its participants. If it turns out that one of the parties to the transaction has not filed a notification, the tax office:
- will send a notice of transactions made by it to the Federal Tax Service of Russia.
At the same time, the inspection may report this to the IFTS at the location of the other party to the transaction. If it turns out that the other party to the transaction has not filed a corresponding notification, it may also be subject to tax liability.
If the transaction is not recognized as controlled (i.e., does not fall under the criteria defined in), the organization is not required to notify the inspectorate of such a transaction.
This procedure follows from the provisions of paragraphs and article 105.16, the Tax Code of the Russian Federation and letters of the Ministry of Finance of Russia dated January 15, 2014 No. 03-01-18 / 746, dated September 6, 2012 No. 03-01-18 / 7-127.
Situation: what date to indicate in the notification of controlled transactions on line 150 "Date of the transaction ..." section 1B. The cost of the goods changed after the sale
In line 150, put the date on which you first recorded income from the sale of goods in accounting. And in line 140 - the final adjusted cost of the goods. In what period did you change the cost of the goods and when did you reflect this in accounting, it does not matter. If the cost of the goods was increased after its sale, separately indicate the amount in the notification additional income and the date of its recognition in accounting is not necessary.
Section 1 of the notification indicates income from controlled transactions according to accounting data. In line 140 "Total cost excluding VAT, excises and duties, rub." section 1B reflect the income from the transaction based on primary documents. In line 150 "Date of the transaction ..." section 1B put the date of recognition of income in accounting. Such rules are established in paragraphs 5.18 and 5.19 of the Procedure for filling out, approved by order of the Federal Tax Service of Russia dated July 27, 2012 No. MMV-7-13 / 524.
Section 1B is drawn up on the basis of the terms of the transaction agreed upon by the parties, that is, taking into account all changes and additions. How to act if the parties changed the transaction price after the sale depends on the period in which this happened.
Answered by Vladislav Volkov,
Deputy Head of the Department for Personal Income Taxation and Administration of Insurance Contributions of the Federal Tax Service of Russia
“The inspectors will compare the income of individuals in 6-personal income tax with the amount of payments in the calculation of insurance premiums. Inspectors will apply this control ratio from the reporting for the first quarter. All control ratios for checking 6-NDFL are given in. For instructions and samples of filling out 6-personal income tax for the first quarter, see the recommendation.
- Download forms
May 22, 2017 is the deadline for submitting a notice of controlled transactions for 2016. Should your organization report on controlled transactions, and what should you pay attention to when preparing a notification in the 1C: Accounting 8 CORP version 3.0 - BUKH.1C program, 1C experts told.
Who must submit the notice
Taxpayers who made transactions in 2016 that are recognized as controlled under Chapter 14.4 of the Tax Code of the Russian Federation are required to submit to tax authorities notification of such transactions (clause 1, article 105.16 of the Tax Code of the Russian Federation).
Based on the information contained in the notification, the tax authorities have the right to verify the completeness of the calculation and payment of taxes in connection with transactions between related parties.
The notification must be submitted by each party to the transaction, including those using special regimes (USN, ESHN, UTII) (clauses 3-4, clause 2, article 105.14 of the Tax Code of the Russian Federation).
If special regimes are used by both parties to the transaction, then such transactions are not controlled (clauses 3, 4, clause 2, article 105.14 of the Tax Code of the Russian Federation).
The form and procedure for filling out a notice of controlled transactions was approved by Order No. ММВ-7-13/ dated July 27, 2012 of the Federal Tax Service of Russia. [email protected] Notification of controlled transactions for 2016 must be submitted no later than May 22, 2017 (Clause 2, Article 105.16 of the Russian Tax Code).
In the program "1C: Accounting 8 CORP" version 3.0, a specialized subsystem for preparing a notification of controlled transactions has been developed, which allows you to automatically fill out, check, print and upload a notification to in electronic format.
What is meant by transaction
The regulatory authorities have repeatedly explained that the term “transaction” for tax purposes is not defined by the Tax Code, therefore this concept is used in the meaning applied by the civil legislation of the Russian Federation (see letters of the Ministry of Finance of Russia dated 04.08.2015 No. 03-01-18 / 44884, dated 13.01 .2014 No. 03-01-18/352).
In accordance with the Civil Code of the Russian Federation, transactions are recognized as actions of citizens and legal entities aimed at establishing, changing or terminating civil rights and duties (Article 153 of the Civil Code of the Russian Federation).
In "1C: Accounting CORP" version 3.0, a transaction means business transactions reflected in the accounting system. In most cases, one transaction is separate line primary document. When automatically generating the initial list of controlled transactions, the program analyzes 17 types of documents - Realization (act, invoice), Receipt (act, invoice), Retail sales report, Equipment receipt, Intangible asset receipt, Fixed asset transfer, Intangible asset transfer etc.
What transactions in 2016 are recognized as controlled
For tax purposes, controlled transactions are transactions between related parties, as well as transactions equated to them, taking into account the provisions provided for in Article 105.14 of the Tax Code of the Russian Federation, namely:
1. Transactions between Russian related parties, if the amount of annual income from these transactions exceeds RUB 1 billion. (clause 1 clause 2 article 105.14 of the Tax Code of the Russian Federation).
2. Transactions between Russian related parties, if one of the parties to the transaction is an MET payer, the subject of the transaction is a mineral subject to MET, and the amount of income for the year from these transactions exceeds RUB 60 million. (clause 2 clause 2, clause 3 article 105.14 of the Tax Code of the Russian Federation).
3. Transactions between Russian related parties, if one of the parties to the transaction applies a special regime (USHN or UTII), and the amount of income for the year on these transactions exceeds 100 million rubles. (clause 3 clause 2, clause 3 article 105.14 of the Tax Code of the Russian Federation).
4. Transactions between Russian related parties, if one of the parties to the transaction is exempt from income tax (including the payer of the simplified tax system) or applies tax rate 0%, and the amount of income for the year on these transactions exceeds 60 million rubles. (clause 4 clause 2, clause 3 article 105.14 of the Tax Code of the Russian Federation).
5. Transactions between Russian related parties, if one of the parties to the transaction applies special income tax benefits, and the amount of income for the year on these transactions exceeds 60 million rubles. (clauses 5 - 7 clause 2, clause 3 article 105.14 of the Tax Code of the Russian Federation).
6. Transactions with foreign related parties, regardless of income (clause 1, article 105.14 of the Tax Code of the Russian Federation, letter of the Ministry of Finance of Russia dated May 10, 2016 No. 03-01-18 / 28673).
7. Transactions between Russian related parties with the participation of independent “formal” intermediaries, regardless of income (clause 1, clause 1, article 105.14 of the Tax Code of the Russian Federation, letter of the Ministry of Finance of Russia dated August 29, 2012 No. 03-01-18 / 6-115).
8. Deals with foreign organizations for goods of world exchange trade, if the amount of income from such transactions with one person per year exceeds 60 million rubles. (subclauses 2, clause 1, clauses 5 - 8 of article 105.14 of the Tax Code of the Russian Federation).
9. Transactions with offshore companies for which annual amount income more than 60 million rubles. (clause 3 clause 1, clause 7 article 105.14 of the Tax Code of the Russian Federation).
It should be borne in mind that the court may recognize the transaction as controlled, even if it does not have the indicated characteristics. This is possible if there is sufficient grounds to believe that this transaction is included in a group of similar transactions made in order to conceal a controlled transaction (clause 10, article 105.14 of the Tax Code of the Russian Federation).
Clause 4 of Article 105.14 of the Tax Code of the Russian Federation defines a list of transactions that are not recognized as controlled, as an exception (for example, interbank loans with a term of up to seven days, transactions for the provision of interest-free loans between Russian related parties, etc.).
In the program "1C: Accounting 8 CORP" version 3.0, most of the controlled transactions are determined automatically. Transactions that are reflected by manual operations or non-standard documents, the user should register with a special document Other controlled transactions, which is available via the hyperlink of the same name from the form .
Which persons are considered interdependent
Criteria for the interdependence of persons, as well as the procedure for determining the share of participation of one organization in another organization or individual in the organization are established by chapter 14.1. NK RF.
In "1C: Accounting CORP" edition 3.0, the list of interdependent persons cannot be determined automatically. Information about interdependent counterparties, including independent formal intermediaries, must be entered in the information register Interdependent persons, which is accessible from the form Controlled Transaction Notification Preparation Assistant.
How to determine the amount of income from transactions
The amount of income from transactions for calendar year is determined by adding up the amounts of income received from such transactions with one person (related persons) for a calendar year, taking into account the procedure for recognizing income established by Chapter 25 of the Tax Code of the Russian Federation (clause 9 of Article 105.14 of the Tax Code of the Russian Federation).
In practice, this means the following:
- the controllability of the transaction is determined by the amount of income from the transaction with the seller, and the concept of "buyer's expenses" is not used;
- it is necessary to take into account the total income on all transactions, and not just the income received by only one party;
- income is determined excluding VAT, excises and duties.
When determining the amount of income from transactions for a calendar year for calculating the sum criterion, the calculation does not include income from transactions that are not taken into account when determining the base for income tax in accordance with Chapter 25 of the Tax Code of the Russian Federation (letter of the Ministry of Finance of Russia dated 13.01.2014 No. 03-01-18 / 349).
In "1C: Accounting 8 CORP" edition 3.0, the amount of income from the transaction is calculated automatically based on the primary documents reflected in the accounting system, but when filling out the notification, the user has the opportunity to adjust the indicators.
Preparation of a notice in "1C: Accounting 8 CORP" (rev. 3.0)
How to get started
To access the subsystem for preparing notifications about controlled transactions, you need to enable the corresponding functionality of the application.
The functionality is configured by the hyperlink of the same name from the section The main thing. Bookmark Controlled transactions you need to set the flag of the same name.
In order for the subsystem to recognize transactions as controlled transactions and subsequently classify them correctly, it is necessary to check the completeness and correctness of filling in the details in the directories Counterparties and Nomenclature, because according to the codes:
- the country of registration in the card of the counterparty is automatically determined if he belongs to offshore zones;
- TN VED in the nomenclature card automatically determines its belonging to the goods of the world exchange trade.
For the convenience of working with controlled transactions, the program is designed Controlled Transaction Notification Preparation Assistant(Fig. 1), accessed via a hyperlink Notification Preparation Assistant(chapter Reports - Controlled transactions).
Preparing a notice of controlled transactions involves three main steps:
- entering initial information and filling out the list of controlled transactions;
- indication additional information for objects that were included in the list of controlled transactions created at the first stage;
- analysis of summary information, formation, verification and uploading of notifications of controlled transactions in electronic form for transmission to the tax authorities.
To fill out the notification, the user just needs to perform all the actions by sequentially clicking on the hyperlinks that are grouped in the form Assistant according to the above steps.
Useful guidance materials for preparing a notification
1. For more information on which persons are recognized as interdependent, and which transactions are recognized as controlled, what consequences the conclusion of these transactions may lead to, see the “Business Directory: legal aspects» in the section «Legal support»
2. For an updated article on the preparation of a notification of controlled transactions in "1C: Accounting 8 CORP" (rev. 3.0), see the section "Technological support for applied solutions"
5. Video recording of a lecture in 1C: Lecture Hall dated 03/24/2016 “Transfer pricing: application practice, preparation of a notice of controlled transactions for 2015 in 1C: Enterprise 8” with the participation of representatives of the Federal Tax Service of Russia and 1C experts.
Some taxpayers must submit to their IFTS no later than May 20 of the year following the reporting year.
When filling out a notice of controlled transactions (), taxpayers must consider some rules.
The controlled transactions notification form can be downloaded.
Instructions for Completing a Notification of Controlled Transactions
When filling out a notice of controlled transactions, you need to remember that:
1. At the end of the year, only one notification is submitted. It should contain information on all controlled transactions made in the reporting year (Letter of the Ministry of Finance dated January 25, 2013 N 03-01-18 / 1-14).
2. The notice is completed either on a computer or by hand in black/blue/violet ink.
3. All notification fields are filled from left to right.
4. Notification text fields are filled in capital letters.
5. The notice may not be corrected in any way by corrective or similar means.
6. Double-sided printing of the notice is not allowed.
7. Pages of the notification are consecutively numbered, starting from the title page. Pages are numbered in the following way: the first is "00001", the second is "00002", etc.
8. If you do not have any indicator, then dashes are put in the familiar spaces designated for its indication. Also, dashes are placed if there is more familiarity than the information indicated. For example, the TIN field contains 12 character spaces, and since the TIN of the organization consists of only 10 digits, this number is indicated in the notification as follows: "7714123456--". True, if you fill out the form on a computer, then you can not put dashes in empty familiarity spaces.
9. Cost indicators are reflected in full rubles (values less than 50 kopecks are discarded, more than 50 kopecks are rounded up to the full ruble).
10. If the notification is filled out by an ordinary individual (not an individual entrepreneur), then on title page it may not indicate its TIN.
11. Despite the fact that in the Procedure for filling out a notification on controlled transactions (approved by Order of the Federal Tax Service of Russia dated July 27, 2012 N ММВ-7-13 / [email protected]) says that the signature of the head of the organization is certified by a seal, an imprint of a round seal is put only if it is available, that is, it is not at all necessary.
12. On the cover page of the notification for 2016 submitted in 2017, indicate your type of activity according to OKVED2 (Letter of the Federal Tax Service dated November 9, 2016 No. SD-4-3 / [email protected]).
Contents of a notice of controlled transactions
The notification consists of a title page, sections: 1A, 1B, 2 and 3. Moreover, if the notification is submitted in relation to transactions with legal entities, then section 2 is filled out in relation to transactions with individuals, individual entrepreneurs, notaries, etc. - section 3.
Notification of controlled transactions: example of filling out
A sample notification of controlled transactions can be viewed
Participants in controlled transactions are required to report annually on their conclusion to the Federal Tax Service by May 20 of the year following the reporting one. The data is formatted in the established . Notification of controlled transactions is submitted to the territorial office of the tax inspectorate electronically or on paper.
For information on how to fill out a notice of controlled transactions, what information should be included in the document, and what threatens for violating the procedure for filing a report with the Federal Tax Service, read the article.
Notice of controlled transactions in 2017: who reports?
The completed document is provided by all taxpayers who made transactions in the reporting year that fall under the definition of controlled. In fact, such transactions are divided into two conditional groups: transactions between interdependent participants and transactions that are equated to interdependent ones.
The first group includes transactions between residents if at least one of the following criteria is met:
- per reporting year the volume of transactions between interdependent residents totaled more than 1 billion rubles;
- the price volume of transactions amounted to more than 100 million rubles, but one of the parties conducts economic and economic activities using a simplified taxation regime (UTII or UAT), while the second participant in economic relations works without the use of special regimes;
- the price volume of transactions amounted to more than 60 million rubles, but one of the participants is obliged to pay the mineral extraction tax, and the subject of the transaction is a mineral that is mined by a resident and is taxed at an interest rate;
- the value of transactions amounted to more than 60 million rubles, but one of the parties to economic relations is exempt from tax liabilities on the profit received due to the fact that he participates in the Skolkovo project or similar investment project subjects of the Russian Federation;
- the volume of income from transactions is more than 60 million rubles, but one of the participants is in economic zone, which implies preferential system taxation tax burden received profit (in comparison with generally accepted taxation conditions in a particular subject of Russia);
- the volume of income from transactions exceeds 60 million rubles, but due to the fact that one of the participants is the holder of a license to use the subsoil of an offshore field or an operator at it, and the tax base this side is determined on the basis of Art. 275.2 Tax Code, including the profit from these transactions, they should be included in the report.
Economic relations equated to interdependent ones are taken into account when filling out a notice of controlled transactions if an additional intermediary party is involved, which is independent. This participant in the transaction performs only organizational functions - it provides the opportunity to perform work or provide services between related parties. He doesn't risk anything. Such transactions do not depend on the volume of the profitable part.
Additionally, controlled transactions are economic relationships regarding foreign trade. It is necessary to submit information to the Federal Tax Service on foreign trade transactions, when their subject is mineral fertilizers, precious metals and stones, oil and goods processed from it, as well as metals, and the volume of income from them with one counterparty amounted to more than 60 million rubles per year.
Transactions are also controlled when the partners are independent, but one of the participants in the relationship is a resident of one of the states approved by the list of Order of the Ministry of Finance No. 108n dated November 13, 2007 (transactions with representatives of such counterparties in Russia are also controlled). The amount of income that falls under control, in this case, should exceed 60 million rubles.
Instructions for Completing a Notice of Controlled Transactions: Preparation
Documentation must be prepared before completing the controlled transactions notification form. The Federal Tax Service has the right to request papers confirming or clarifying the terms of the transaction, starting from June 1 of the year following the reporting one.
The algorithm for preparing documentation for the Federal Tax Service on controlled transactions:
- Identification of transactions that fall under control. The stage implies the need to identify which of the completed transactions are recognized as controlled (Article 105.14 of the Tax Code).
- Planning for the collection of documents. At this step, one should estimate the volume tax payments, as well as the cost of preparing papers.
- Definition characteristic features transactions. Here there is a specification of the properties of works, services or goods (subjects of transactions), for which cooperation is recognized as controlled, as well as a comparison with each other to recognize homogeneity.
- Comparison of financial or commercial indicators economic relations under contracts. At this stage, the interdependent parties of transactions and their description should be analyzed.
- Taking into account the results of the previous paragraphs, it is necessary to determine the volume of the income from transactions for tax purposes.
- Holding economic analysis and documentation. It is necessary to compare income from transactions with market prices and determine the profitability of economic relations.
Documents may be required for any controlled transaction, so they should be prepared in advance. Be sure to monitor the relevance and reliability of the data.
How to fill out a notice of controlled transactions
The notification form consists of a title page and four sections. Each block must be filled with correct and up-to-date information. Corrections and strikethroughs in the notification are not allowed. If the taxpayer made a mistake or entered inaccurate data, he can send an updated report to the Federal Tax Service at the place of registration.
Care must also be taken to ensure that the medium on which the notification is provided is not damaged. For example, if the document is submitted on paper, it is not allowed to staple it.
There is one cell for each character in the notification form. The only exception is the date. Empty fields are not left. If there is no data, a dash is put in each cell.
Text fields are filled with capital letters. Numerical values less than 50 kopecks are not prescribed, and if there are more than 50 kopecks in the indicator, it is rounded up to the ruble.
Start writing signs on the left. If there are less of them than the number of cells, dashes are put on the right.
Filling out the title page
The title page of the notification contains the data of the taxpayer and the department of the Federal Tax Service, such as:
- OKATO;
- number of the department of the Federal Tax Service;
- full name of the organization;
- Full name of the authorized person of the company or individual taxpayer;
- economic activity code;
- contact phone number and email address.
In addition, the year for which the report is being submitted should be indicated. In the indicated place, a signature must be affixed confirming the accuracy of the information provided in the report, and a seal (if any).
Completing Section 1A
The block is filled with data separately for each controlled transaction or group of transactions that are recognized as homogeneous. It indicates generalized information about the subject of economic relations, as well as the amount of income received from financial and economic activities. Indicators of profit and expenditure are determined based on the data of financial statements.
The number of such blocks should correspond to the number of conducted controlled transactions. If the transactions were recognized as homogeneous and combined into a group, then one generalized section 1A is filled out.
Completing Section 1B
The number of these blocks depends on the number of sections 1A, as they are an addition. This section contains data on deliveries, shipments, work performed or services rendered.
The section reflects the names of the contracts, the dates of their conclusion, the territorial place of the transaction. It also indicates the quantity of goods and the price per unit, as well as the cost of the entire transaction. The date of commission is indicated in accordance with the data of the financial statements.
The summation of goods (services, works) within one controlled transaction is prohibited. It is necessary to register data for each unit of the subject of economic relations. The number of sheets in such a section must be the same as the number of transactions in a group of deals.
Completing sections 2 and 3
These blocks contain data on transactions in relation to organizations, while the information in section 1B is not taken into account. If the subject of financial and economic activity did not have transactions with counterparties, which are indicated in the sections, these sheets do not need to be included in the notification.
Responsibility for failure to submit data to the Federal Tax Service on controlled transactions
Organizations are required to provide information on controlled transactions to the Federal Tax Service within the specified time limits. The information must be current and reliable. Otherwise, the company will be held administratively liable.
If the organization does not provide information about such transactions in a timely manner, it faces a fine of 5,000 rubles. The same applies to the provision of incorrect data on controlled transactions with counterparties.
If the company hid profits from controlled transactions, the fine will be much higher - 20% of the amount of tax that was not paid, but not less than 100,000 rubles.
To avoid penalties, please review the Sample Controlled Transaction Notice Form.
An example of how to fill out a notice of controlled transactions (2017) can be found below.
The threshold for foreign trade transactions with foreign affiliates is proposed to be increased to 60 million rubles. Currently, any such transaction, regardless of its amount, is recognized as controlled (). And this means that the taxpayer is obliged to annually notify the tax office about them ().
It is also planned to raise the minimum threshold for controlled transactions between Russian persons. If now it is 1 billion rubles. (clause 2, article 105.14 of the Tax Code of the Russian Federation), then in the future it can be increased to 2-3 billion rubles. This initiative was confirmed yesterday by the Deputy Director of the Department of Tax and Customs Tariff Policy of the Ministry of Finance of Russia Andrey Kizimov.
At the same time, the department considers it appropriate to release from tax control transactions for the provision of interest-free loans and guarantees between related Russian parties (persons whose relationship may affect the terms or economic results their activities). Now such transactions are recognized as controlled, and any income that could be received from them should be taken into account for tax purposes ().
Find out what obligations arise for an organization or individual who is a controlling person in relation to a foreign company in the material. "Controlled foreign companies and controlling persons in Solution encyclopedias Internet version of the GARANT system. Get free access for 3 days!
The changes may also affect the materiality criterion for controlled transactions in order to reduce the number of notifications sent to the tax authorities. "Now many companies, in order to protect themselves, provide information on all minor transactions - naturally, these are additional costs for the company and a burden on the Federal Tax Service of Russia. We propose to introduce a materiality criterion - 5% of the organization's revenue, but not more than 10 million rubles. That is , tax service should not require documentation for small transactions, and there may be quite a lot of such transactions in the company,” Andrey Kizimov comments.
In addition, in 2016 there may be changes in the framework tax reporting transfer pricing (the sale of goods or services by related parties at intercompany, different from market prices). “In foreign practice, the so-called “cross-country report” is now being introduced, when the parent company of the holding submits a report to its tax authority, and the latter, in turn, sends information on the company’s foreign divisions to the countries where they are located. We also want to go exactly this way, so that Russian holdings submit a report to the Federal Tax Service of Russia, and then it itself sends the relevant information to foreign jurisdictions.Accordingly, we expect from foreign companies that such a report will come to Russia not from subsidiaries located here, but from foreign parent companies companies through the system of foreign tax authorities,” Kizimov says. According to him, the largest Russian holdings are interested in this standard being introduced already in current year. And as soon as it works, organizations will be able to submit a unified report to the Russian tax authorities, and they will no longer need to send documents to each jurisdiction of this holding. The expert also clarified that for the first time, companies will be able to apply such a standard on a voluntary basis. This requirement will become mandatory no earlier than 2017-2018.
