International group of companies (MGK) documentation
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Preparation of documentation for an international group of companies (MGK)
If your organization is a member of an international group of companies whose consolidated turnover exceeds 50 billion rubles, then it is obliged to prepare three-tier documentation for the Russian tax authorities.
Similar requirements are established by the laws of other states, in this regard, these documents can be prepared at the group level. We will be happy to develop documentation or check previously prepared documentation for compliance with legislation.
WHAT DOCUMENTATION DO YOU NEED TO PREPARE?
The documentation submitted by the MGK participants includes the following documents:
1. Notice of participation in MGK;
2. Country data on the MGK, namely:
Notification of participation in MGK is filled in according to the established format and involves the identification of the participants of the MGK and its parent company.
The notification is submitted to the tax authority no later than 8 months from the date of the end of the financial year of the international group of companies.
Country-by-country report (CbCR) is filled in according to the established format and contains the disclosure of the following data:
the total amount of income from transactions for the reporting period;
the amount of capital;
the amount of profit before tax;
the amount of calculated and the amount of paid income tax;
the amount of accumulated profit;
the amount of tangible assets;
number of employees.
A Russian company submits a Country Report if it is the parent company of the Group or a member of the Group authorized to submit this report for the Group no later than 12 months from the date of the end of the reporting period.
In other cases, the Russian company submits the Country Report within 3 months from the date of the request from the tax authorities.
Global Documentation (Master File) is presented in an arbitrary format and must contain:
information about the structure of the international group of companies;
description of the MGK's activities;
a description of the main factors affecting the financial result;
information on the markets in which the MGK members operate;
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functional analysis of the participants of the MGK.
Terms of submission of the Global Documentation: within three months from the date of receipt of the request from the tax authorities. Documentation can be requested no earlier than after 12 months from the date of the end of the reporting period.
National Documentation (Local File) is presented in any form and contains detailed information on intra-group transactions concluded with the participation of a Russian company, as well as:
the structure of the governing bodies of the Russian company;
a description of the activities of the Russian company;
justification of the conformity of prices to the market level;
functional analysis of intra-group transactions.
Terms of submission of National documentation: 30 days from the date of receipt of the request from the tax authorities. The documentation may be requested no earlier than June 1 of the year following the calendar year in which the controlled transactions were made.
"Country-by-country report" (CbCR);
"Global documentation" (Master File);
"National documentation" (Local File).
COST OF PREPARATION OF DOCUMENTATION FOR IGC
The cost of preparing documentation for MGK depends on the size of the Group and the number of companies and jurisdictions included in the reports, as well as on the number of controlled transactions carried out by a participant in the MGK with foreign counterparties.
When ordering our transfer pricing services, you can count on a quick solution of issues, identification of risks and professional advice from leading experts.
OUR SERVICES
The list of services provided by Nika Commerce includes a whole range of services for the preparation of documentation for international groups of companies:
Analysis of the structure of the group of companies to determine whether the Russian organization is a member of the MGK;
Determination of the existence of grounds for exemption from reporting under the MGK;
Preparation of notifications on participation in the MGK according to the format approved by the Federal Tax Service of Russia;
Preparation of a country report and global documentation in the format approved by the Federal Tax Service of Russia;
Preparation of national documentation taking into account the requirements contained in the Tax Code of the Russian Federation;
Oral and / or written advice on MGK issues.
Fill out the form and our specialist will contact you as soon as possible and prepare an individual offer
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