We would like to remind you that Russian companies, members of multinational enterprise group shall report with regard to 2019 fiscal year as follows:
- Submit a Notification on participation in the MNE Group based on the results of the Reporting Fiscal Year. Please, note that the notification shall be submitted to the Tax authorities electronically not later than 8 months after the last day of the Reporting Fiscal Year of the MNE Group’s ultimate parent company.
- Provide the country-by-country data of the MNE Group consisting of the following documentation:
- Master File.
- Local File (Local Transfer pricing documentation).
- Country-by-Country Report.
The Master File shall be submitted by the MNE Group’s participant upon request of the Tax authorities following 3 months (but not earlier than 12 months after the end of the Reporting Fiscal Year).
The Local File shall be submitted similarly within 30 days of receiving the request from the Tax authorities, but not earlier than December 31 of the year following the Reporting Fiscal Year when the controlled transaction took place.
The Country-by-Country Report is provided by the ultimate parent company of the MNE Group within 12 month after the end of Reporting Fiscal Year. MNE Group’s participants shall be liable to submit the CbC Report electronically upon the request of the Tax authorities unless it can be obtained by them due to the Multilateral Competent Authority Agreement on the Exchange of Country-by-Country Reports.
Please contact Emerging Markets Group experts for further details.