Russia (RU)

Jurisdiction Overview

363 *Tax Rulings: Are unilateral cross-border tax rulings (e.g. advance tax rulings, advance tax decisions) available in laws or regulation, or in administrative practice? Yes
 Data Date: 2019


Contrary to the IBFD (IBFD 2019b), according to the OECD, Russia can issue the following rulings: "(i) rulings related to preferential regimes (special economic/industry zones); (ii) cross-border unilateral advance pricing agreements (APAs) and any other cross-border unilateral tax rulings (such as an advance tax ruling) covering transfer pricing or the application of transfer pricing principles; (iii) cross-border rulings giving a unilateral downward adjustment to the taxpayer’s taxable profits in the country giving the ruling; (iv) permanent establishment rulings; and (v) related party conduit rulings" (OECD UTR 2018: 388).


OECD UTR 2018: 388
IBFD 2019b