Russia: 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
See MoreRussia: A draft order regarding tax exchange information published
The Federal Tax Service (FTS) has released a draft order on 26th October 2015 that contains a list (in Russian) of countries and territories which do not exchange tax information with Russia for discussion purposes. According to article 25.13-1 of
See MoreRussia: Wheat export duty amended
The Russian Government has amended the method for calculating wheat export duty that was in force from 1st July 2015. The government has increased the deductible portion of the wheat export duty from 5,500 rubles ($83.9) to 6,500 rubles ($99.1)
See MoreRussia: Tax authority issues an official order on tax treaty application
The Russian government issued Order No. 1531-r on 8th August 2015. This Order relates to an agreement between Russia and Kazakhstan on the recognition of official documents authorizing the tax residence of taxpayers for the purpose of tax
See MoreRussia: MoF clarifies income tax treatment of remuneration paid to remote employees
The Finance Ministry (MoF) issued letter No. 03-04-06/40525 on 15th July 2015 for clarifying the income tax treatment paid by a Russian employer to employees working on a remote basis abroad. The MoF noted that the income tax treatment
See MoreRussia: Exemption from excise duties on export of excisable goods
The Russian Finance Ministry issued Letter No. 03-07-15/41049 on 16th July 2015 clarifying the application procedure for exemption from excise duties on export of excisable goods. On the basis of changes introduced by Federal Law No. 150-FZ,
See MoreRussia: Authorization for signature to tax agreement with Hong Kong
The Government of Russia has authorized the Finance Ministry to sign the draft text of the tax agreement between Hong Kong and Russia and it was released on 6th August 2015 for public
See MoreRussia: Input VAT deductibility on imported goods
The Finance Ministry has issued letter no. 03-07-15/31200 on 29th May 2015 to clarify the deductibility of VAT input tax on goods imported into Russia if the taxpayer has received a hard copy of the electronic customs declaration from the customs
See MoreRussia: Federal Council accepts amendments on CFC rules
The Russian Federation Council has accepted draft law, No. 714002-6 on 3rd June 2015 that contains changes to the Controlled Foreign Company (CFC) rules and the tax residency idea. It was signed by the President and officially published on 8th June
See MoreRussia: Convention on Mutual Administrative Assistance in Tax Matters enters into force
The Multilateral Convention on Mutual Administrative Assistance in Tax Matters has entered into force in regard to Russia on 1st July 2015. The Convention and the amending protocol apply to Russia from 1st January 2016. The agreement is intended
See MoreRussia: Corporate tax rate freeze
The Russian President has stated that tax rates will be frozen for the next four years and has indicated that he wants to encourage new and growing businesses. The Government also has a plan to announce investment incentives for existing
See MoreChina and Russia: DTA signed
The Double Tax Agreement (DTA) between China and Russia has been signed on 8th May
See MoreRussia: Appeal Court agrees that payments made under a sham transaction are not tax deductible
The Appeal Court of Russia has ruled in Case no. А40-28065/13 on 25th February 2015 regarding fees paid for the use of know how. The fees are not deductible for corporate income tax purposes if the transaction is a fake. Summary of the case: LLC
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