Netherlands 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).
See MoreRussia and China draft a new DTA
On February 5, 2014, Russia completed the drafting of a new double taxation agreement (DTA) with China to replace their 1994 treaty. The new treaty when finalized is likely to update the provisions to take into account changes in the tax
See MoreRussia: Ministry of Finance clarifies the transfer pricing rules
The Ministry of Finance Letter No. 03-01-18/53941, issued on 10 December 2013, clarifies the rules to determine the income for controlled transactions purposes. The Ministry of Finance specified that transactions defined in article 105.14 of the Tax
See MoreRussia’s draft DTAs with Belgium and China
On 5 February 2014, Russia's draft Double Tax Avoidance Agreements with China and Belgium were tabled before Russia's Cabinet for its
See MoreRussia Considers Tax Break for Landlords
Russia's Economic Development Ministry has recently proposed cutting tax rates for citizens who lease their apartments. This measure aims to reduce the numbers of unregistered landlords. The proposal involves reducing the tax on rent revenues to
See MoreRussia considers Tax on Foreign Online Retailers
Russia is considering whether to levy a 30 percent tax on imports from foreign online retailers and restrict the number of parcels imported. The proposed tax, which would be imposed on imports worth more than RUB7, 000 (USD 202), is intended to
See MoreRussia- Financial Services
Under Federal Law 39-FZ and 420-FZ, from 1 January 2015 interest on related party loans should be charged at market rates and documentation should be maintained to demonstrate
See MoreRussia: Ministry of Finance clarifies patent system taxation issues
The Ministry of Finance published Letter No. 03-11-09/55604 on 17 December 2013 which sets out the maximum and minimum thresholds of potential annual income to apply with regard to the patent system of taxation. The MoF also clarified that under
See MoreClarification of Russian MoF on tax withheld not in accordance with the tax treaty
Russian Ministry of Finance has published a letter no. 03-03-06/4/44331 which was issued on 23 October, 2013. This explains if corporate withheld tax by a Bulgarian branch belongs to a Russian company may be benefited against the corporate tax
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