Russia: Publishes the draft procedure on multilateral APAs
The Russian Finance Ministry on 3 March 2017, published a draft Procedure outlining the process for handling multilateral Advanced Pricing Agreements (APAs). The Procedure is intended to enable a taxpayer to conclude an APA in relation to a foreign
See MoreRussia: Clarifications on carry-forward of CFC losses
The Ministry of Finance (MoF) issued Guidance Letter No. 03-04-05/5577(2 February 2017), clarifying the issue of losses incurred by a controlled foreign company (CFC) on 7 March 2017. The Ministry of Finance identified that, under Article 25.15,
See MoreRussia: Simplified expense deduction for corporate income tax purposes
The Federal Tax Service on 21 February 2017, explained the deduction of expenses for Corporate Income Tax (CIT) purposes. Accordingly, a taxpayer may deduct expenses from corporate income in the tax period in which they are incurred, regardless of
See MoreDTA between Russia and Spain: Russia clarifies taxation of dividends paid to non-resident
The Russian Ministry of Finance (MoF) on 22 February 2017, issued Guidance Letter No. 03-08-05/73316 of 7 December 2016, clarifying the taxation under the Russia - Spain Income and Capital Tax Treaty of the dividends derived by a Spanish
See More7 more countries sign tax co-operation agreement to enable BEPS Action 13
According to a press release of 27 January 2017, published by the OECD, as part of continuing efforts to boost transparency by multinational enterprises (MNEs), Gabon, Hungary, Indonesia, Lithuania, Malta, Mauritius and the Russian Federation have
See MoreLithuania, Russia signed the Multilateral Competent Authority Agreement for CbC reporting
According to a press release of 27 January 2017, published by the OECD, Lithuania, Mauritius, Gabon, Hungary, Indonesia, Malta, and the Russian Federation have now signed a tax co-operation agreement, the Multilateral Competent Authority Agreement
See MoreBelgium approves DTA with Russia
On 23 December 2016, the Belgian Council of Ministers approved the double tax agreement (DTA) with Russia for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income. Once in force and effective, the
See MoreRussia: Submits a bill related to tax deductible R&D expenses
The government on 23 November 2016 submitted a bill to the lower house of the parliament on amending the list of deductible costs relating to research and development (R&D) for corporate income tax purposes. The main requirements are discussed
See MoreChina Proposes FTA with Russia and others
China's Deputy Minister of Commerce has proposed that the member countries of the Shanghai Cooperation Organization (SCO) – China, Kazakhstan, Kyrgyzstan, Russia, Tajikistan, and Uzbekistan should establish a free trade agreement (FTA). At the
See MoreRussia: Adopts changes to the Tax Code
The State Duma adopted in the first hearing draft Law No. 11078-7 (the Law) on 2 November 2016, regarding changes to the Tax Code and other legislative provisions. The main provisions of the Law are summarised below: Carry-forward of losses: The
See MoreRussia: 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
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