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Development of the Russian Tax Service’s position on taxation of intragroup services

By Dzhangar Dzhalchinov, Boris Bruk, Anna Zvereva, and Lidia Charikova | 17 August 2020
  • Domestic tax advice
  • Tax risk management

Finance Ministry proposes confiscating funds illegally moved offshore

We already presented our vision of general trends in the taxation of intragroup services in our alert on the most […]

By Dzhangar Dzhalchinov, Valentin Larin, and Lidia Charikova | 20 March 2020
  • Domestic tax advice
  • Tax risk management

Development of court practice on taxation of corporate restructurings

On 13 February 2017 the Commercial Court of Vladimir Oblast delivered a judgement in case No. А11-6203/2016 (the “Judgement”) under […]

By Dzhangar Dzhalchinov, Nikolai Roudomanov, and Irina Lifanova | 17 February 2017
  • Domestic tax advice
  • International tax advice
  • Tax risk management

Indirect sale of real estate in the Russian Federation in the context of the beneficial ownership rules

On 17 January 2017 the Commercial Court of Vladimir Oblast delivered a judgement in case No. А11-6602/2016 (the “Decision”) under […]

By Boris Bruk | 1 February 2017
  • Domestic tax advice
  • International tax advice
  • Tax risk management

Development of Russian court practice on tax implications when dividends are paid to foreign companies (application of the “beneficial owner” concept).

On 13 October 2016 the Commercial Court of Kemerovo Region delivered a judgement in case No. А27-20527/2015 (the “Decision”) under the […]

By Dzhangar Dzhalchinov | 22 November 2016
  • Domestic tax advice
  • Tax risk management
  • Transfer pricing

Development of the practice of determining market price for tax purposes in arm’s-length transactions

On 1 August 2016 the Commercial Court of the Republic of Tatarstan delivered a decision in case No. А65-2248/2016 (the […]

By Dzhangar Dzhalchinov | 5 October 2016
  • Domestic tax advice
  • Tax dispute resolution
  • Tax risk management

Development of practice on treating of facilities as immovable property for the purpose of imposing corporate property tax

On 12 July 2016 the Commercial Court of Moscow rendered a decision in case No. А40-98958/16-108-827. This case considered a […]

By Dzhangar Dzhalchinov | 2 August 2016
  • Domestic tax advice
  • Tax dispute resolution
  • Tax risk management

Development of court practice in tax disputes over accounting of expenses to pay for intragroup services

On 23 May 2016 the Commercial Court of the North Caucasus Region delivered a ruling in the case of Bonduelle-Kuban […]

By Dzhangar Dzhalchinov | 28 July 2016
  • Domestic tax advice
  • Tax incentives
  • Tax planning
  • Tax risk management

Development of the tax practice of the “beneficial owner” concept

On March 3, 2016 the Commercial Court of Moscow rendered a decision on case No. А40-241361/15 (the “Decision”) under the […]

By Dzhangar Dzhalchinov | 5 April 2016

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