NewsCase StudiesEvents

Russia: Law amending CFC and corporate tax residence rules signed and published

Also in the news...

UK-Norway Iceland Liechtenstein free trade agreement

Business guidance, reports and other documents to help you understand the UK-Norway, Iceland, and Liechtenstein free trade agreement (FTA).

Essential Steps Before Launching an International Auction Business

Expanding a business internationally presents unique challenges, particularly when that business involves auctions. The global auction market continues to grow as more entrepreneurs see its potential for reaching new customers across borders. However, success in this specialised field requires careful planning and the right technological foundation.

Innovative Welsh exporter puts Britain at the forefront of global immunisation efforts

UK Export Finance supports renewable energy tech company Dulas to deliver life-saving vaccine refrigerators to over 80 countries worldwide.

British aerospace manufacturers to benefit from UK-US trade deal

British aerospace manufacturers to benefit from UK-US trade deal as further details announced

PM secures new agreement with EU to benefit British people

UK secures new agreement with the European Union to support British businesses, back British jobs, and put more money in people’s pockets.

Russia: Law amending CFC and corporate tax residence rules signed and published

Back to News

The President of the Russian Federation signed on 29 December 2017, Law No. 436-FZ of 28 December 2017 (the Law), which amends the Tax Code and several legislative acts. The Law was thereafter published in the official government portal. It provides for the following main changes in controlled foreign company (CFC) rules:

  • the process of calculating the CFC taxable base for transactions involving financial assets is brought up to date with recent developments;
  • income derived from certain genuine transactions in derivative instruments will be considered as active income (CFC income is exempt if active income equals or exceeds 80% of the total CFC income);
  • the below actions performed in Russia by/on behalf of foreign companies will not be interpreted as evidence of Russian corporate tax residence:
  1. drafting minutes of meetings of the board of directors;
  2. drafting minutes of meetings of the shareholders;
  3. planning and administering activities of the foreign company by a related party; and
  4. administering works performed outside Russia related to the exploration or extraction of mineral resources;
  • implementation of rules on calculating the CFC taxable base of a foreign consolidated group;
  • enactment of rules on the CFC exemption for a multistage ownership structure;
  • introduction of taxation on individuals upon the sale of assets that were acquired after the liquidation of a CFC; and
  • extension of the list of activities of foreign companies that do not lead to a permanent establishment in Russia.

Article supplied by the Fiducenter

You are not logged in!

Please login or register to ask our experts a question.

Login now or register.