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  • Article

    Beneficial Ownership Concept New Interpretation From The Russian Federal Tax Service

    Beneficial Ownership Concept New Interpretation From The Russian Federal Tax Service.
    RussiaCorporate/Commercial Law
    KINANIS LLC
    KINANIS LLC
  • Article

    The Government Of The Russian Federation Has Approved The Treaty Between The Russian Federation And Belarus On General Principles Of Taxation On Indirect Taxes

    The Treaty covers VAT and excise duties, for which the national legislation is to be brought into conformity with the Treaty by January 1, 2023.
    RussiaTax
    GRATA International
    GRATA International
  • Article

    BVI Ready To Disclose Beneficiaries

    For many, this might turn into an unexpected addition of 20% profit tax plus fines and penalties on top of 13% personal income tax.
    RussiaTax
    Goltsblat BLP LLP
    Goltsblat BLP LLP
  • Article

    Tax Treaty News

    Within the mutual agreement procedure provided for under Article 25(3) of the Luxembourg-Russia Double Tax Treaty, the tax authorities of both countries agreed on a uniform interpretation of Article 10 (2) of the treaty...
    RussiaTax
    ELVINGER HOSS PRUSSEN, société anonyme
    ELVINGER HOSS PRUSSEN, société anonyme
  • Article

    Funds Received Free Of Charge: A New Tax Risk?

    The method of transferring of funds free of charge, used by many foreign investors to finance their Russian subsidiaries, is again threatened by adverse tax consequences.
    RussiaAccounting and Audit
    Salans LLP
    Salans LLP
  • Article

    Confirmation Of Direct Investment In Capital To Apply A Reduced Tax Rate On Payment Of Dividends

    On 30 December 2016 the Commercial Court of Voronezh Oblast delivered a judgement in case No. А14-10190/2014 (the "Decision") under the claim of Ilyushin Finance Co. Open Joint Stock Company...
    RussiaTax
    Dentons
    Dentons
  • Article

    Development Of Court Practice Of Determining Direct Capital Investment For The Purpose Of Applying The 5% Withholding Tax Rate When Paying Dividends To A Cypriot Company

    On 3 May 2017 the Commercial Court of Chelyabinsk Region rendered a decision in case No. А76-20508/2016 under the claim of Chelyabenergosbyt PJSC (the "Company").
    RussiaTax
    Dentons
    Dentons
  • Article

    Presidential Decree On Suspension Of Certain Provisions Of International Tax Treaties Of The Russian Federation Published

    On 15.03.2023 the Ministry of Finance of Russia and the Ministry of Foreign Affairs of Russia made a proposal to the President of the Russian Federation to issue a decree on suspension of double taxation agreements...
    RussiaTax
    GRATA International
    GRATA International
  • Article

    Russia Ratifies MLI

    The Multilateral Convention to Implement Tax Treaty-Related Measures to Prevent Base Erosion and Profit Shifting of 24 November 2016 - also known as the Multilateral Instrument (MLI)
    RussiaTax
    Gorodissky & Partners
    Gorodissky & Partners
  • Article

    Definition Of The Russian Tax Residency For Individuals - Potential Changes?

    The Russian Federal Tax Service ("FTS") has prepared a letter clarifying criteria for determining the Russian tax residency for individuals (the "Letter").
    RussiaTax
    Withers LLP
    Withers LLP
  • Article

    Development Of Russian Court Practice On Taxation Of Dividends Distributed To A Russian Branch Of A Foreign Parent Company

    On 4th of October 2016 the Commercial Court of Tambov Region delivered a judgment in case No. А64-3695/2016 under the claim of "Uvarovsky Sugar Plant" Closed Joint Stock Company.
    RussiaTax
    Dentons
    Dentons
  • Article

    RF Supreme Court Consolidates Court Practice On The Application Of Transfer Pricing And Thin Capitalization Rules

    On February 16, 2017, the Presidium of the Supreme Court of the Russian Federation approved the Review of Court Practice in the Consideration of Cases Involving the Application...
    RussiaTax
    Dentons
    Dentons
  • Article

    Development Of The Tax Practice Of The "Beneficial Owner" Concept

    On March 3, 2016 the Commercial Court of Moscow rendered a decision on case No. А40-241361/15 (the "Decision") under the claim of BANK INTEZA joint stock company (the "Russian Company").
    RussiaTax
    Dentons
    Dentons
  • Article

    Multilateral Convention On Implementation Of BEPS Plan Signed

    On June 7 2017 Russia, alongside 68 other states and jurisdictions, signed the Multilateral Convention to Implement Tax Treaty-Related Measures to Prevent BEPS, which was developed to implement Action 15 of the BEPS Plan.
    RussiaTax
    Gorodissky & Partners
    Gorodissky & Partners
  • Article

    Practice Of Applying The Beneficial Owner Concept Develops Rapidly.

    2016 was marked by a breakthrough in the practice of applying the concept of the person beneficially entitled to income (the beneficial owner concept)...
    RussiaTax
    Dentons
    Dentons
  • Article

    Russia Moves Towards A More Transparent International Tax Policy

    Russia is one of the fastest growing markets for the international wealth management industry.
    RussiaTax
    Withers LLP
    Withers LLP
  • Article

    Russia/Switzerland Double Tax Treaty Revision – New Protocol Signed

    The officials of the Russian and Swiss governments have now confirmed that the Protocol to the existing double tax treaty (‘Protocol’) was signed in Washington DC last week.
    RussiaTax
    Withers LLP
    Withers LLP
  • Article

    Russia Moves To Terminate Netherlands Tax Treaty

    Awaiting decision with regards to the denunciation by the Russian government of the Double Tax Treaty with the Kingdom of Netherlands- potential consequences.
    GlobalTax
    AGPLAW | A.G. Paphitis & Co. LLC
    AGPLAW | A.G. Paphitis & Co. LLC
  • Article

    RF Supreme Court Praesidium Overview: Foreign Investor Protection Disputes

    Among other things, the Overview presents the RF SC Praesidium's stand on several issues deriving from tax disputes involving foreign investors.
    RussiaTax
    Goltsblat BLP LLP
    Goltsblat BLP LLP
  • Article

    TM Assignment And Withholding Tax

    Goltsblat BLP advises of a tax dispute judgement passed by a court of appeal that is of importance to the business community.
    RussiaTax
    Goltsblat BLP LLP
    Goltsblat BLP LLP

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