Russia: Application on Participation exemption in case the subsidiary is reorganized
The Ministry of Finance has issued Letter No. 03-03-РЗ-15941 on April 8, 2014 clarifying the application of the participation exemptions in the case where the subsidiary is subject matter to reorganization. Pursuant to general rule, for qualifying
See MoreRussian Parliament adopts Law to permit FATCA Disclosures
The Russian parliament has allowed a bill to permit financial institutions to observe with the United States’ Foreign Account Tax Compliance Act (FATCA). US Congress has passed FATCA in 2010, which will be effective on July 1, 2014 and it is
See MoreRussian banks help IRS after new FATCA law passed
The State passes legislation allowing Russian banks to pass information on their U.S. clients to the IRS, as demanded by the Foreign Account Tax Compliance Act (FATCA). FATCA will come into force on July 1, 2014, and by this time the law that
See MoreRussia: Clarification of tax treatment of income derived from alienation of immovable property
The Ministry of Finance has issued Letter No. 03-08-05/13287 on March 26, 2014 describing the income tax treatment derived by an Israeli individual from alienation of an immovable property situated in Russia. Article 6 of the Israel - Russia Income
See MoreRussia: Draft law on information exchange with foreign tax authorities
The Russian government has allowed a draft law initiating the process of information exchange with foreign tax authorities on May 14, 2014. The law introduces the responsibility of Russian credit organizations, brokers, depositaries, insurance
See MoreNew Russian CFC and anti-avoidance legislation
The amended draft law regarding controlled foreign companies and other anti-offshore measures has done most valuable changes in the field of foreign tax structures and tax avoidance. This law has publicly available on 27 May, 2014. It highlights
See MoreMalta – Russia DTA
On May 22 2014 the double taxation agreement (DTA) between Malta and Russia is to enter into force. Under the agreement, withholding tax on dividends paid from Russia is restricted to 5% where the recipient company has a 25% shareholding in the
See MoreUS May Close Door on Russian FATCA IGA Talks
Talks with Russia on an intergovernmental agreement (IGA) in connection with the FATCA legislation have been suspended by the US. The aim of the agreement if reached would be to enable foreign financial institutions (FFIs) in Russia to comply with
See MoreNetherlands Agrees to Amend the Russian DTA
The Netherlands are to begin negotiations with Russia to amend the double taxation agreement (DTA) concluded in 1996, with a first round of negotiations expected to be held in June 2014. Russia has asked for a revision to the agreement to bring it
See MoreRussian Appeal Court rules on thin capitalization
Russia’s Arbitration Court of Appeal issued a decision on 24 February 2014 holding that a loan from a foreign related company of United Bakers Pskov LLC1 was subject to the thin capitalization legislation. This ruling by the Court was made on the
See MoreRussia-Malta DTA ratified
On 2 April 2014 Russia ratified the double taxation agreement (DTA) signed with Malta. The tax treaty between Malta and Russia was signed on 24 April 2013 and ratified by Malta on 18 June 2013. This DTA provides for lower withholding tax rates on
See MoreRussia: treaty between Russia and Italy clarified by the Ministry of Finance
Letter No. 03-08-РЗ/10213 published by the Russian Finance Ministry explains the position with respect to dividends paid by Russian companies to Italian parent companies. The participation exemption is available if the parent company meets a 365
See MoreRussia Clarifies transfer pricing for Domestic Transactions
Letter No 03-01-18/2080 issued by the Russian Finance Ministry on 22 January 2014 clarifies that some domestic transactions are to be subject to the transfer pricing rules as they are deemed to be controlled transactions for this purpose. These
See MoreRussia Plans Crimean Special Economic Zone
Russia has confirmed that the process of making the Crimea a part of Russia is likely to require amendments to the tax system and this may involve the provision of temporary tax incentives for companies located in the Crimea. Other changes would
See MoreRussia: Condition related to Financial Services
According to the transfer pricing rules, interest that is not disallowed may be subject to the thin capitalization provisions. Certain specialized provisions may apply where one of the parties to a transaction is a
See MoreRussia – Investment in Russian SEZs Increases in 2013
The Special Economic Zones (SEZs) set up by Russia attracted an increased amount of investment in 2013, totalling RUB 30.2 billion in the year. Revenues of RUB 50 billion were earned in the zones, and 3,145 new jobs were created. The Russian
See MoreRussia: Clarification regarding tax treatment
On 18 December 2013 the Russian Ministry of Finance (MoF) published Letter No. 03-08-05/55702, clarifying the tax treatment of contractual penalties paid by a Russian company to a Ukrainian company for violation of the contractual terms. According
See MoreRussia: Clarification regarding residence rules of partnership income
The Russian Ministry of Finance (MoF) allotted Letter No. 03-08-05/1229,on 17 January 2014, clarifying whether income received by a US partnership may be subject to tax according to the Russia–United States Income and Capital Tax Treaty (1992).
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