As just over a year has passed since the entry into force of the new transfer pricing rules, we now have an opportunity to analyze the impact of the new rules on the largest Russian and international companies in the oil & gas sector operating in Russia. Over half the respondents confirmed that at present they are reviewing the current business model or structure of contractual relations in the group, while three of the 12 companies are planning or implementing reorganization.
In addition, the respondents believe that the
following are the key difficulties encountered during the adaptation process:
- the significant volume of information required on the controlled transactions (10 out of 12 companies),
- the need to modify the accounting system (8 out of 12 companies),
- the lack of automation of processes (7 out of 12 companies),
- the instability of tax legislation (7 out of 12 companies).