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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January 2019 was marked by an upsurge in court activity in considering issues related to Russian companies’ filing of notices of participation in foreign entities and notices of controlled foreign companies (СFСs). Four cases considered by the Moscow Commercial Court caught our attention at once: the Moskabelmet,[1] INFRASTRUKTURA TK,[2] Almera[3] and Inspektorat R cases.[4]

Continue reading “Development of court practice on notification of participation in foreign entities and of controlled foreign companies” →

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.

Continue reading “Expiration of the second round of the Russian voluntary disclosure (capital amnesty) campaign and the tax-exempt liquidation of CFCs” →

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” →