On 22 August 2012, the Cabinet of Ministers issued a procedure for concluding binding transfer pricing (TP) agreements between large taxpayers and the State Tax Service (STS). The procedure applies with effect from 1 January 2013. The procedure provides the templates for TP agreements and also the standard application forms. The TP methods and the procedures for calculating arm's length prices will be determined in the TP agreement. According to the procedure, STS has to analyse the TP agreement applications within 20 days, plus 30 days for inquiries and verification of the information. In case of a negative decision, taxpayers...