The Ministry of Finance has issued Letter No. 03-03-РЗ-15941 on April 8, 2014 clarifying the application of the participation exemptions in the case where the subsidiary is subject matter to reorganization. Pursuant to general rule, for qualifying participation exemption, the parent company has to satisfy minimum 365 days holding period and not less than 50% shareholding in the company paying the dividends. Lastly, the Ministry of Finance clarified that for the objectives of application of the participation exemption, the holding period computes commences from the moment of the state registration of the new reorganized subsidiary.
Related Posts
Russia and Abkhazia sign tax treaty
Russia and Abkhazia took a significant step towards economic cooperation by signing an income tax treaty, on 7 May, 2024, marking the agreement as a first between the two regions. The treaty, once ratified, will prevent double taxation and
Read MoreRussia: MoF clarifies tax exemption for CFC amid treaty suspensions
The Guidance Letter No. 03-12-11/2/11449, published by the Russian Ministry of Finance (MoF) on 12 February, 2024, addresses the tax exemption applicable to profits of Controlled Foreign Companies (CFCs) situated in jurisdictions with which Russia
Read MoreHong Kong releases synthesised text of BEPS MLI-affected tax treaty with Russia
The Hong Kong Inland Revenue Department (IRD) has released the synthesised text of the tax treaty with Russia, as affected by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting
Read MoreRussia: Parliament considers overhauling simplified taxation system for businesses
The Russian parliament is currently considering a draft bill that aims to modify the thresholds governing the application of the simplified taxation system for legal entities. Key provisions under consideration include: Employee Threshold
Read MoreRussia: Central bank maintains key interest rate at 16%
On 22 March 2024, the Russian Central Bank declared its decision to maintain the key interest rate at 16%. The key rate is a crucial factor for tax purposes regarding the safe harbor rates applied to interest income and expenses related to
Read MoreRussia proposes progressive individual income tax system
Russia's parliament is considering a major change to its income tax system, proposing a progressive structure with higher rates for the wealthiest individuals. Under the proposed plan, earners making up to 5 million rubles (approximately $68,000
Read More