Russia Federal Tax Service (FTS) has issued Letter No. ШЮ-4-13/2827@ of 13 March 2025, concerning the notification of controlled transactions. The letter clarifies that from 2024, it is mandatory for taxpayers to disclose as part of the notification the transfer pricing method used to justify the arm's length (market) price of a controlled transaction. Further, it is clarified that the transfer pricing method must be reflected in the transfer pricing documentation submitted at the request of the tax authority. Lastly, it is noted that a penalty of RUB 100,000 is imposed for failing to timely submit the notification or for...