The Agency is discussing the application of advance pricing agreements under contracts entered into in the international arena, said the head of service.
MOSCOW, 20 Nov. FNS is considering the use of advance pricing agreements to foreign trade transactions, said the head of the service Mikhail Mishustin in interview to the newspaper “Kommersant”.
He reminded that currently the Federal tax service concludes with the taxpayer advance pricing agreements within the framework of transfer deals. Such transactions may be used by related parties to reduce the tax base.
“You give us information on the prices at which implement some raw materials. We, if it’s a commodity, looking at average prices. If the deviation is not higher than 10-12% — sell, but if the above — we check for this and are afraid,” — said Mishustin.
To reduce the risk of additional taxes on such transactions, the company may enter into with the Federal tax service of the deal before agreeing on a price. Currently this is only possible in relation to domestic transactions.
“Now we are discussing the possibility of using such agreements to foreign trade transactions — taking into account international practices and the exchange of information with foreign tax administrations,” — said Mishustin.
Currently, he said, FNS has obtained 82 of the draft advance pricing agreement, by their examination, issued 69 decisions, concluded 25 agreements on pricing, which are 42 of the largest taxpayer of the Russian Federation. “This is a significant reduction of tax risks both for them and for the budget,” he said.