On February 15, 2016 the President of the Russian Federation
signed Federal Law No. 32-FZ on Amendments to Parts One and
Two of the Russian Federation Tax Code (Regarding Taxation of
Profits of Controlled Foreign Corporations and Income of Foreign
Entities) (the "Law").
The Law introduces a number of amendments to the RF Tax Code
regarding application of the rules on controlled foreign
corporations ("CFCs") that are intended,
as the authors of the Law have noted, to resolve issues of applying
those rules in practice and to minimize tax hurdles for honest
taxpayers.
The following are some of the key amendments presented by the
Law:
- The rules for calculating a CFC's profit/loss for profit
tax purposes have been clarified: for example, the taxpayer now has
the right to choose between two ways of calculating profit/loss of
a CFC (calculation based on financial statements compiled for the
financial year according to the domestic law of the CFC or
according to the
