Russia: 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
See MoreChina signs a new tax treaty with Russia
China and Russia entered into a new double taxation treaty which was signed on October 13,
See MoreRussia: VAT treatment of electronic services
The Finance Ministry (MoF) has issued a Letter No. 03-07-08/35579 on 21 July 2014 clarifying the VAT treatment of services for giving entrance to an electronic database supplied by a foreign company to a Russian company. As a result, the MoF
See MoreRussia: VAT free event and exhibitions for foreigners
The Finance Ministry of Russia has established that exhibition, live event and conference services provider in Russia to non-Russian customers are free from Russian VAT. But according to EU and the OECD Guidelines, VAT should be charged on live
See MoreRussia: Obligatory notification for dual nationality or foreign residence permits requires
Russia acted out a law that effective from 4 August 2014 requiring Russian citizens to give notice to the Federal Migration Service (FMS) where they have dual nationality, or foreign residence permits. For Russian citizens who already have dual
See MoreRussia: Revised version of the draft law publishes
The Ministry of Finance in Russia has released a significantly revised version of the draft law on the package of tax initiatives on September 2, 2014. This contains a number of significant changes affecting such matters as exclusions from
See MoreRussia: Zero VAT rate applicable to freight services provided by certain vessels
The Finance Ministry (MoF) has issued Letter No. 03-07-РЗ/32218 on July 3, 2014 describing the VAT rate applicable to the provision of services of seaborne vessels and combined navigation vessels based on time charter agreements for the reason of
See MoreRussia: Simplification in VAT invoice
Businesses those are VAT registered in Russia will no need to deliver consumers along with full VAT receipts from 1st October 2014. The VAT invoices in Russia must be delivered within 5 days of the provision of the service or goods. This change will
See MoreRussia: Interest derived by a foreign company is subject to CIT
The Finance Ministry has released Letter No. 03-00-08/2/29954 that describes the tax treatment applicable to interest paid by a Russian resident individual to a foreign company on the basis of loan agreement. In accordance with article 246 of tax
See MoreRussia: No VAT on foreign IP sales
Intellectual property means the rights or license for copyrights, trademarks and patents to apply. According to the Federal Tax Service, the sales for Intellectual Property (IP) by a foreign company to a Russian company for apply outside of Russia
See MoreRussia: New model for TIEA adopted
The Russian government adopted Ordinance No. 805 on August 14, 2014 that permitted the model for the tax information exchange agreement (TIEA) to be finished by Russia with foreign states. The TIEA is based on the model agreement on exchange of
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