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 judgement in case No. А64-3695/2016 under the claim of “Uvarovsky Sugar Plant” Closed Joint Stock Company (the “Company”). Continue reading “Development of Russian court practice on taxation of dividends distributed to a Russian branch of a foreign parent company”

Development of Russian court practice on tax liabilities of permanent establishments that accept expenses from theirs foreign head offices

On 29th of June 2016 the Commercial Court of Moscow delivered a judgement in case No. А40-51925/16 under the claim of the Austrian company Strabag AG (the “Company”), which carries out business in Russia through a permanent establishment. The case is a logical continuation of a series of cases previously considered by the Russian commercial courts on determination of tax base for foreign entities’ permanent establishments(such as, for example, the Freshfields case, the Gide Loyrette Nouel Vostok case, and the MI Drilling Fluids UK Limited case). The court ruled against the Company. Continue reading “Development of Russian court practice on tax liabilities of permanent establishments that accept expenses from theirs foreign head offices”