On February 20, 2025 Valentin Moiseev, when speaking at the annual conference “Tax Policy and Tax Disputes 2024–2025” arranged by “Pravo.ru”, told the audience about various tax risks associated with payment of royalties to Russian contracting parties.
Tax authorities always take interest in payment of royalty. It is not tangible, it cannot be measured or weighed, therefore questions re: correctness of its assessment thereof always arise”, noted Valentin.
Valentin also added that, when it comes to royalties, the Federal Tax Service first of all asks to explain how the price was determined and what is the business purpose of the deal. Evidence of actual use of items covered by exclusive rights is also important. Tax inspectors will be vigilant where parties are related entities, pricing is non-transparent, and know-how is mentioned in the contract.
A detailed video is available in the “Insights” section at the following link.
