Russia: 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
See MoreRussia: 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
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