The Federal Tax Service has recalled the deadline for notification of controlled transactions in 2025

The Federal Tax Service has recalled the deadline for notification of controlled transactions in 2025
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The Federal Tax Service reminded participants in transactions subject to transfer pricing rules: notification of controlled transactions for 2025 must be submitted no later than May 20, 2026. We are talking about transactions between related parties and those equated to them when meeting the criteria of art. 105.14 of the Tax Code of the Russian Federation.

The Federal Tax Service has fixed a specific deadline for the transfer block of reporting: legal entities and individuals who made controlled transactions in 2025 must send a notification to the inspection at the place of registration no later than May 20, 2026. The format is electronic, the form is CND 1110025.

Transactions between related parties and those equated to them are considered controlled if the conditions and summative criteria prescribed in Article 105.14 of the Tax Code of the Russian Federation are met. For a business, this means a simple check: it is important to confirm that you meet the criteria in advance, and not at the moment when the deadline is already on.

The Federal Tax Service and practitioners separately pay attention to the quality of the data in the notification. In case of incomplete information or errors, you can submit a clarification, but a fine of 100,000 rubles is provided for failure to provide notification or false information. This is a fine from the category of those that are "insulting to receive" — it is not directly related to the amount of the transaction and often occurs due to failures in collecting information between the financial service, the legal unit and the group of companies.

In order to pass the reporting season calmly, companies should pay in advance:

  • collect a list of potentially controlled transactions for 2025
  • verify the interdependence and criteria according to art. 105.14 of the Tax Code of the Russian Federation
  • check uploads from the accounting system and primary sources
  • assign a person responsible for group data consolidation
  • set aside time for clarification if discrepancies in amounts or counterparties come up.