Tax Messenger
Summaries of key tax and legal developments in legislation and case law and the latest issues affecting human resource management, prepared by B1's experts in Russia
Transfer pricing in UAE: declaration period and new FTA explanations
With the 30 September 2026 deadline for filing the 2025 corporate tax return approaching, companies should focus on ensuring the accurate disclosure of transactions with Related Parties and Connected Persons in the TP Disclosure Form.
UMMC: revised time limits for decisions to initiate transfer pricing audits
On 29 April 2026, the Moscow District Arbitration Court issued a ruling in the Ural Mining and Metallurgical Company case No. А40-72524/2025 regarding the time limits for ordering transfer pricing audits of tax calculations and payments in related party transactions. Both at first instance and on appeal, the case was ruled in favor of the taxpayer, but these rulings were quashed by the court of cassation.
Currency regulation in Kazakhstan: transactions lacking apparent economic substance
In April 2026, amendments to the Rules for Currency Transactions in the Republic of Kazakhstan entered into force, introducing, inter alia, the concept of transactions lacking apparent economic substance.
Draft procedure for payment of technology fee published
The Russian Ministry of Industry and Trade has published a draft Government Decree establishing the procedure and deadlines for the payment of a technology fee. The Fee is scheduled to come into force on 1 September 2026 and, as previously reported, it will apply to electronic devices that are manufactured in or imported into Russia. The Fee will be payable by manufacturers and importers of such devices – both legal entities and individual entrepreneurs.
Regulatory and tax control shifts in the IT sector: areas to focus on in early 2026
The end of 2025 was marked by numerous changes in IT regulation. When considered as a systemic whole rather than individually, they indicate several trends that should be taken into account when assessing tax risks and opportunities for software and database developers – including members of corporate groups – and their clients.