Partner and head of Dentons’ Russian Tax and Customs practice Dzhangar Dzhalchinov, counsels Boris Bruk, Igor Schikow and Alexey Matveev have been ranked among the Indirect Tax Leaders 2018 by the International Tax Review. Continue reading “Four Dentons Russian Tax and Customs practice lawyers ranked among the best tax leaders by Indirect Tax Leaders 2018”
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Feb 22nd, 2018 By Dzhangar Dzhalchinov and Natalia Vagina
On 5 February 2018, the Arbitration Court of Moscow Region delivered its decision (hereinafter, the “Decision”) on ZKK VODOKANAL (the “Company”) (case No. А41-50945/17). The case considered the issue of determining the moment when the right to apply Moscow regional property tax incentive arises (hereinafter, the “Incentive”). Continue reading “Development of court practice regarding regional tax incentive application regarding real estate fixed assets in Moscow Region”
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Feb 21st, 2018 By Dzhangar Dzhalchinov, Boris Bruk, Irina Lifanova and Nikolai Roudomanov
On 19 February 2018 the President of Russia signed three federal laws[i] which extended the capital amnesty campaign and timeframes for tax-exempt liquidation of foreign companies and unincorporated structures. Continue reading “New capital amnesty”
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Aug 14th, 2017 By Dzhangar Dzhalchinov and Nikolai Roudomanov
On 2 August 2017 the Commercial Court of Kaliningrad Region delivered its decision (the “Decision”) on NPO Digital Television Systems (the “Company”) (case No. А21-2521/2017). The Decision is currently about the only positive example of the most recent court practice of the Russian courts dealing with application of the concept of the “person beneficially entitled to income” (the beneficial owner concept). Continue reading “Development of court practice regarding application of the beneficial owner concept”
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Jun 27th, 2017 By Dzhangar Dzhalchinov and Valentin Larin
On 16 June 2017 the RF Supreme Court rendered a ruling in case No. А42-7562/2015. In this case the court considered a dispute between Murmansk Trawl Fleet PJSC (hereinafter MTF) and the Federal Tax Service Interdistrict Inspectorate for Major Taxpayers in Murmansk Region. One of the subjects of the case was the charging of personal income tax on amounts paid to an employee by agreement between the employee and the employer at termination. Continue reading “Development of court practice on tax disputes over charging personal income tax on amounts paid to employees by agreement at termination of employment”
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Jun 23rd, 2017 By Dzhangar Dzhalchinov and Nikolai Roudomanov
On 7 June 2017 the Russian Federation signed the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (the “Multilateral Convention”[1]). The Multilateral Convention was developed by the countries that are members of an Ad Hoc Group of the Organisation for Economic Cooperation and Development as part of implementing “Action 15” under the Plan to Prevent Base Erosion and Profit Shifting (BEPS). The Multilateral Convention makes it possible to implement the provisions of the BEPS Plan without amending existing agreements on avoidance of double taxation (“Tax Agreement”). Each jurisdiction may choose the provisions it considers acceptable for itself (other than mandatory provisions) and notify their treaty parties of this. Continue reading “Russia’s accession to the Multilateral Convention to implement measures under the BEPS Plan”
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May 24th, 2017 By Dzhangar Dzhalchinov and Gennady Timonichev
Dentons’ Tax and Customs practice congratulates its clients and friends on the end of the first stage of transfer pricing compliance for 2016 – the filing of the notification of controlled transactions completed in 2016! Continue reading “Transfer pricing compliance in Russia. Part 3. Stages of transfer pricing compliance”