Russia: Law concerning notification process of CFCs adopted
The parliament has approved Law No. 667946-6 on 27th March 2015 for extending the deadline of tax resident’s notification about the involvements held in controlled foreign companies (CFCs). The deadline for notification has been extended from 1st
See MoreRussia: State Duma considers new draft law regarding thin capitalization rules
The Russian State Duma Council accepted the decision on 17th February 2015 to incorporate a new draft of Law No. 724609-6 on the introduction of changes to Article 269, Part 2 of the Tax Code regarding the meaning of controlled debt. The draft law
See MoreRussia: Application for participation exemption by a tax agent
The Finance Ministry (MoF) has issued Letter No. 03-03-06/1/885 on 19th January 2015 for describing the application of the participation exemption by a tax agent giving dividends to a Russian company. In accordance with article 284 (3) of the Tax
See MoreRussia: State Duma passes new tax law without extension of thin capitalization rules
The President has signed a new law on 8th March 2015 for changing article 269 of the Russian Tax Code. Precisely, the provisions of extending thin capitalization rules to foreign affiliates and bank loans are excluded from the new law. Under Russian
See MoreRussia: Amendments to transfer pricing rules have entered into force
On the basis of Federal Law No. 379-FZ, the amendments has made in transfer pricing (TP) rules and it was issued on 29th November 2014. This amendments to TP rules have entered into force on 1st January 2015. The important changes are given
See MoreRussia: Guidance on definition of related parties
The Finance Ministry (MoF) has issued Letter No. 03-01-18/1989 on 23rd January 2015 describing the rules for definition of a company and its employees as related parties for transfer pricing determinations. The MoF considered that the meaning of
See MoreRussia: The MoF clarifies requirements to claim tax deduction of expenses
The Federal Tax Service has released Letter No. 03-03-10/4547 to clarify the requirements that must be completed by the primary accounting documents and it was issued by the Ministry of Finance (MoF). In accordance with the article 252 and article
See MoreRussia: Clarifications on computing taxable income of CFCs published
The Ministry of Finance (MoF) has released Letter No. 03-03-06/1/68300 describing the process to calculate the taxable income of controlled foreign companies (CFCs) for the purposes of taxation in Russia. The letter was issued on 29th December 2014.
See MoreRussia: Draft law on the thin capitalization rule submitted to State Duma
The Draft Law No. 675906-6 regarding the introduction of changes to article 269 of part 2 of the Tax Code in respect to the meaning of the concept of controlled indebtedness has been submitted to the State Duma on 16th December 2014. A
See MoreRussia: Federal Arbitration Court has made decision regarding tax audits of adjusted tax returns
A Russian company naming “OJSC RN Holding (OJSC)” has submitted adjusted tax returns for June, August and December 2009 to the tax authority and claimed a reduction of the excise tax liability paid upon excise good’s importation to Russia.
See MoreRussia: Taxation of Controlled Foreign Companies and other anti-offshore measures
The amendments to the Tax Code on CFC, has focused on the following matters: Controlled foreign companies Beneficial ownership Tax residence determination by the company's management place Taxation of real estate transactions Criminal
See MoreRussia: Law providing CFC rules signed
The President of Russia has signed a Federal Law No. 376-FZ for introducing the CFC rules on 24th November 2014. The law enters into force with effect from 1st January
See MoreThe Finance Ministry clarifies income allocation and expenses to Russian PE
The Finance Ministry (MoF) has published a Letter No. 52359 for describing the allocation of income and expenses to a Permanent Establishment (PE) in Russia of a non-resident company and it has issued on 17th October 2014. In accordance with article
See MoreRussia: President signs new tax monitoring law
The Russian President has signed the Federal Law No. 348-FZ on 4th November 2014 that enacts a new tax administration regime for large taxpayers in respect of the exchange of information between tax authorities and taxpayers. This tax monitoring
See MoreRussia: CFC law has been adopted by the Federal Council
The Federal Council has adopted the draft law on 19th November 2014 that initiates the CFC rules. There is no significant change in the adopted law compared to the previous draft. This law will enter into force with effect from 1st January
See MoreRussian Parliament to Consider Revised Draft of CFC Law
On 22 October 2014 the Russian parliament received a new version of the draft law on controlled foreign companies (CFCs). Parliamentary hearings on the latest draft law are to take place on 11 November 2014. Generally the draft law aims to
See MoreChina signs new tax treaty and protocol with Russia
China signed a new income tax treaty and protocol with Russia on 13 October 2014. The key changes made in the new treaty are: In Article 4, “place of effective management” has been included as a one of the criteria for determining residency
See MoreCourt decides that the provision of tax treaties between Germany & Russia do not obstruct the application of thin capitalization rules
The Federal Arbitration Court of the Moscow decides that the provision of tax treaties between Germany & Russia do not obstruct the application of thin capitalization rules. The Federal Arbitration Court of the Moscow Circuit (FAC) decided in
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