Since January 1, 2026, amendments to the Tax Code have come into force, significantly expanding the scope of transactions subject to tax control. Previously, only transactions between related parties or with residents of offshore zones were considered controlled. Now, transactions with residents of countries where the corporate income tax rate is 15% or lower are also included.
This change directly affects many Russian entrepreneurs, especially those doing business with partners from the CIS and the Middle East. In particular, the new criteria apply to counterparties from Uzbekistan (15%), Kyrgyzstan (10%), Moldova (12%), Qatar (10%), Oman (15%), Georgia (15%), Serbia (15%), as well as the UAE (9%) — the latter have been removed from the offshore list but retain a low tax rate.
What Has Changed for Businesses
The expansion of controlled transactions brings several serious consequences:
Increased reporting burden — transfer pricing documentation must now be prepared and submitted for such transactions.
Stricter tax audits — tax authorities have gained more tools to monitor transfer pricing.
Higher risk of additional assessments and fines — failure to comply with the new requirements is subject to fines, which have increased significantly since 2024.
Key Uncertainties for Taxpayers
In a letter dated January 28, 2026, the Ministry of Finance stated that it would not compile an official list of countries falling under the new rules. Businesses must assess compliance with the 15% threshold themselves. Furthermore, it remains unclear which tax rate should be considered — the nominal (statutory) rate or the effective (preferential) rate actually applied by the counterparty.
For example, in China, the nominal corporate income tax rate is 25%, but a counterparty may benefit from a preferential rate of 15%. Would a transaction with such a counterparty be considered controlled? There is no answer yet. In essence, the absence of official clarifications shifts the burden of proof onto the taxpayer, making their position more vulnerable by default.
What Businesses Should Do Now
Acsour experts recommend that companies do not wait for clarifications but act proactively:
Compile a list of foreign counterparties whose transactions may fall under control.
Analyze the corporate income tax rates in the jurisdictions of your partners (both nominal and effectively applied).
Request supporting documents from counterparties — certificates, tax returns, or other evidence of the applicable rate.
Develop an internal position on how to identify controlled transactions and document it properly.
Establish a transfer pricing risk management system — practice shows that tax authorities are significantly more lenient toward companies that have such a system in place.
How Acsour Can Help
Acsour experts are ready to:
conduct an audit of your cross-border transactions to determine whether they fall under the new criteria;
assist in compiling a list of controlled transactions and preparing the necessary documentation;
develop internal policies and a documented position to support you during tax audits.
Contact us — we will help you assess risks, establish a transfer pricing management system, and protect your business from additional assessments and fines.