Russia: New version of draft law on BEPS Action 13 implementation issued
The Finance Ministry has issued a new version of the draft law on 6th September 2016 regarding BEPS Action 13 implementation. The draft law proposes the following topics: BEPS related compliance: Documentation requirement: Master file: As per the
See MoreRussia: Notification of tax authorities concerning CFCs
The Finance Ministry (MoF) has issued a Letter No. 03-01-23/30779 on 27th May 2016 for clarifying the responsibility of taxpayers to notify the tax authorities about CFCs. On the basis of section 3.1 of article 23 of the Tax Code, taxpayers have to
See MoreRussia: Draft Order for approving CFC notification form published
According to the Russian Tax Code, individuals and companies are needed to notify the tax authority of controlled foreign companies (CFC) of which they are considered controlling persons. Note that, these companies and individuals are considered to
See MoreRussia: MoF clarifications regarding interim dividends
The Finance Ministry (MoF) has issued a letter No. 03-03-06/2/21011 on 13th April 2016 describing the tax treatment of interim dividends paid by a Russian company to its company shareholders in an amount exceeding the net profits of the company in
See MoreRussia: List of documents substantiating exemption of CFC profits
The Federal Tax Service (FTS) has published a Letter No. ED-3-13/1427 on 4th April 2016 for describing the time limits for submission to the tax authorities of notifications on controlled foreign companies (CFCs) and the necessary documents
See MoreRussia: Draft law on CbC reporting requirements issued for public consultation
The Russian Finance Ministry has issued a draft law regarding the introduction of country-by-country (CbC) reporting in Russia on 8 April 2016. The CbC reporting requirements would apply only to international groups whose aggregate revenue according
See MoreRussia: FTS clarifies tax treatment of dividends received by a foreign company
The Federal Tax Service (FTS) has issued a letter no. SD-4-3/2765 on 19th February 2016 for clarifying the tax treatment of dividends received by a foreign company which voluntarily chooses to be considered as a Russian tax resident. According to
See MoreRussia: Amendments to CFC rules entered into force
The president of Russia has signed Federal Law No. 32-FZ on February 15, 2016 that amends the СFC provisions. This Law has published on 15th February 2016 and will enter into force on 1st January 2017. For bank loans that will already be exempt
See MoreRussia: Amendment in thin capitalization rules passed
Federal Law No. 25-FZ amending the thin capitalization rules was passed by the Parliament on 15 February 2016. As per the amended thin capitalization rules, interest on loans from banks and Russian companies will not be subject to the thin
See MoreRussia: Amendments to CFC rules adopted by lower chamber
The lower chamber of the parliament has passed in the third reading the draft Federal Law No. 724609-6 amending the thin capitalization rules on 29th January 2016, which was submitted to the lower chamber of the parliament on 14th December 2015. It
See MoreRussia: Draft list of countries and territories not exchanging tax information
The Federal Tax Service (FTS) has published an amended version of the draft Order regarding a list of countries and territories which do not exchange tax information with Russia on February 1, 2016. In the amended list Austria, Israel, Lebanon,
See MoreRussia: Amendment of tax law implements in 2016
In Russia, recently important tax laws were passed for corporate taxation from 2015 onwards, which will take effect from 2016. The major changes are given below: In 2016, an interest rate threshold from 75% to 125% for the Central Bank will apply
See MoreRussia: Draft amendments to CFC rules
A draft of Federal Law No. 953192-6 regarding the СFC provisions was submitted to the lower chamber of the parliament on 14th December 2015. The CFC provisions were first provided by the Tax Code and Federal Law No. 376-FZ of 24 November 2014. The
See MoreRussia: MoF clarifies interest expense regarding loans
The Ministry of Finance (MoF) has recently released Letter No. 03-03-06/1/63388 to clarify the applicable tax treatment of interest expense incurred on a loan used to pay dividends. According to Article 252 of the Tax Code (TC) a taxpayer may
See MoreRussia: Decision regarding related party’s liability published
The Supreme Court of Russia upheld the decisions of the lower courts regarding case No. A40-153792/2014 on 2nd November 2015. The Court stated that a newly established company (LLC "SU-91 Injstroyset" (LLC)) which is related to a taxpayer (ZAO
See MoreRussia: MoF clarifies determination of tax residence status in case of dual resident
The Finance Ministry (MoF) of Russia has issued a clarification on 30th October 2015 regarding the determination of the tax residence of an individual under the Income and Capital Tax Treaty (1996). The MoF clarified that his status should be
See MoreRussia: FATCA compliance for national banks
The Central Bank of Russia has published a letter No. 1245/2568 on 13th November 2015 for describing the process of how Russian financial institutions (RFI) should apply the Foreign Account Tax Compliance Act (FATCA). In accordance with Federal
See MoreProtocol to a treaty between Russia and Singapore signed
Russia and Singapore signed an amending protocol to the Russia - Singapore Income Tax Treaty (2002) on 17 November 2015, in Moscow. Further details will be reported
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