Changes to currency regulation rules for individuals

On 2 December 2019, the President of the Russian Federation signed Federal Law No. 398-FZ (“Law No.398-FZ”) which made the latest significant amendments to the Federal Law on Currency Regulation and Currency Control (the “Currency Regulation Law”). The amendments, that were adopted, will affect individuals who are currency residents of Russia (“Residents”) and have accounts at foreign banks.

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Changes to currency regulation rules for individuals

On August 2, 2019, the President of the Russian Federation signed Federal Law No. 265-FZ (the “Law”) amending the Federal Law on Currency Regulation and Currency Control (the “Currency Regulation Law”).

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CFC declaration campaign 2019

Dentons tax experts would like to remind you that 20 March 2019 is the deadline for filing notifications of controlled foreign companies (“CFC”) with the Russian tax authorities. Controlling persons must file CFC notifications in respect of corporate and non-corporate CFC (trusts, funds, partnerships). In 2019, controlling persons must declare CFC profits or losses that were recognized by Russian taxpayers in 2018.

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Expiration of the second round of the Russian voluntary disclosure (capital amnesty) campaign and the tax-exempt liquidation of CFCs

Dentons’ Russian Tax team would like to remind you that 28 February 2019 is the deadline for filing a special declaration with the Russian tax authorities to participate in the voluntary disclosure campaign (the so-called “capital amnesty campaign”).[1] In addition, Russian tax resident individuals must liquidate their controlled foreign companies and non-corporate structures (trusts, partnerships and others) no later than 1 March 2019 for tax-exempt receipt of the liquidation proceeds.

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New capital amnesty

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”

Development of court practice regarding application of the beneficial owner concept

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”

Russia’s accession to the Multilateral Convention to implement measures under the BEPS Plan

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”