Federal Law No. 539-FZ, enacted on 27 November 2023, introduced significant amendments to Section V.1 of the Russian Tax Code.
These changes directly affect the application of the Federal Tax Service’s letter No. ШЮ-4-13/6384@ dated 22 May 2022 to transactions where income and/or expenses are recognised from 1 January 2024 onwards – regardless of when the contract was signed.
One key update is the reinforced requirement to explicitly specify in the documentation and notifications for controlled transactions the exact method used to justify that the pricing is in line with market value.
Reference Document: <Letter> of the Federal Tax Service of Russia dated 13 March 2025 No. ШЮ-4-13/2827@
<On Ensuring the Proper Application of the FTS Letter No. ШЮ-4-13/6384@ of 25 May 2022>
These changes directly affect the application of the Federal Tax Service’s letter No. ШЮ-4-13/6384@ dated 22 May 2022 to transactions where income and/or expenses are recognised from 1 January 2024 onwards – regardless of when the contract was signed.
One key update is the reinforced requirement to explicitly specify in the documentation and notifications for controlled transactions the exact method used to justify that the pricing is in line with market value.
Reference Document: <Letter> of the Federal Tax Service of Russia dated 13 March 2025 No. ШЮ-4-13/2827@
<On Ensuring the Proper Application of the FTS Letter No. ШЮ-4-13/6384@ of 25 May 2022>