Russia’s existing rules, which were only designed to be temporary, date back to 2000 and are widely considered to be in need of overhaul.
“The current rules are quite primitive,” said Ruslan Vasutin, a tax partner at DLA Piper in Russia. “One of the well-known deputies of the Russian Parliament, Andrey Makarov, who was heavily involved in drafting of the Russian Tax Code, once said that the Russian transfer pricing rules had been adopted in such a form on purpose so as to never actually function in practice.”