ARTICLE · 26 JULY 2007

Russia’s Draft Black List On Participation Exemption

Deloitte AG

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A law published 16 May 2007 introduces a European-style participation exemption regime in Russia. Under the new regime, which comes into effect on 1 January 2008, dividends received by Russian parent companies from qualifying participations will be exempt from tax.

SwitzerlandTax

Stephen Baumann

Vladimir Gidirim

Dimtry Gusev

Stefan Laganà

Impact For Swiss Corporations

A law published 16 May 2007 introduces a European-style participation exemption regime in Russia. Under the new regime, which comes into effect on 1 January 2008, dividends received by Russian parent companies from qualifying participations will be exempt from tax. On 18 July 2007 the Russian Finance Ministry published (on its internet site www.minfin.ru) a draft "black list" of non-qualifying countries, which influences the ability to benefit of the Russian participation exemption. Almost all known offshore jurisdictions have been included into the list along with some taxing jurisdictions like Cyprus, Luxembourg, Belgium, the United States (Delaware, Wyoming, US Virgin Islands) and ex-UKdependent territories (Jersey, Guernsey, Sark, Alderney) are on this list. The canton of Zug is mentioned on the "black list" as well, whereas all other Swiss cantons remain unaffected according to this published draft. Dividends from companies located in other cantons

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