Russia–MNE Tax

Americas

US Senate Finance Committee Chair Ron Wyden and Senate Finance Committee Member Rob Portman release bipartisan bill to disallow foreign tax credits for companies that pay taxes to Russia, other tax benefits: United States Senate Committee on Finance→

April 11, 2022

Americas

US Internal Revenue Service has suspended tax information exchanges with Russian tax authorities in response to Russian war against Ukraine; no information has been shared since Feb. 24 invasion: David Lawder / Reuters→

April 6, 2022

Europe

EU’s ATAD 3 `unshell’ directive could be improved to freeze Russian oligarchs’ assets more efficiently by extending additional obligations, including the publication of financial statements and nexus to the register of ultimate beneficial owners: Renáta Bláhová / The Slovak Spectator→

March 21, 2022

Africa

US Senate Democrat leaders said they were `exploring legislation’ to eliminate the tax credits US companies get for paying taxes in Russia, which would put Russia on a list with Iran, North Korea, Sudan, and Syria: The Hill→

March 21, 2022

Belarus

UK announces it is suspending exchange and sharing of tax information with Russia and Belarus, meaning Russia will no longer receive information under any of the UK’s agreements: exchange of information on request, common reporting standard or country-by-country reporting: Gov.uk→

March 18, 2022

Americas

US Senate Finance Committee Chair Wyden proposes to cancel preferential GILTI rate on Russian and Belarusian income, and deny foreign tax credits and deductions for taxes paid to Russia and Belarus: Ron Wyden / US Senate Commitee on Finance→

March 14, 2022

Africa

E-invoicing and interaction with transfer pricing: a Middle East and African perspective

October 25, 2021

Rubeena Dina and Aniruddha Saha, GTS Africa, discuss the global trend of tax authorities’ introducing electronic invoicing requirements and the implications for transfer pricing in the Middle East and Africa . . .

Americas

Brazil, China, Russia MAP tax dispute resolutions could improve, peer reviews show

October 19, 2021

There are signs that the competent authorities of Brazil, Russia, and China have insufficient resources to keep up with their caseloads for resolving tax and transfer pricing disputes through mutual agreement procedure (MAP), according to peer review reports released October 18 by the OECD, while . . .

Russia

Russia proposes new taxes on digital services provided by foreign tech firms with aim to spur growth of domestic alternatives: Reuters→

September 14, 2021

Americas

US R&D tax incentives will be among least generous unless Congress acts, study finds

September 8, 2021

The US will drop to a rank of 32nd among a peer group of 34 large economies in terms of its tax support for research and development (R&D) if it allows the new requirement to amortize R&D expense to take effect as scheduled in 2022, according to a September 7 study from . . .

Americas

ICAP multilateral tax risk assurance program applications due September 30

September 2, 2021

Multinational entities interested in participating in the first full round of the OECD Forum on Tax Administration (FTA) International Compliance Assurance Programme (ICAP) have until September 30 to submit the . . .

Accounting

Russia clarifies R&D expense accounting for tax purposes, associated reporting

August 25, 2021

The Russian Ministry of Finance on July 20 published guidance on the procedure for accounting for research and development (R&D) expenses for income tax purposes under article 262 of the Russian tax code (Letter No 03-03-06/1/49733, dated June 24), and also covers . . .

Asia-Pacific

Russia looking into revising tax treaties with Switzerland, Hong Kong, and Singapore, according to government official, following three other recent treaty revisions and renunciation of Dutch treaty: Fahad Shabbir / UrduPoint News→

August 23, 2021

Africa

Countries take diverse transfer pricing approaches to financial transactions, profit attributions

August 4, 2021

Updated transfer pricing country profiles released by the OECD on August 3 include for the first time information on 20 reviewed countries’ transfer pricing rules applicable to . . .

Asia-Pacific

Russia’s new double tax treaty policy: the score is 3 to 1

August 4, 2021

Roustam Vakhitov, Crowe Expertiza, analyzes Russia’s new tax treaty policy following the government’s June 7 notice to the Dutch government of Russia’s intent to terminate the double tax treaty between the two countries after a failure to . . .

Africa

Ireland, Lithuania, Hungary offer lowest tax rates for R&D, OECD study finds

August 2, 2021

An OECD taxation working paper on corporate effective tax rates for research and development (R&D) released on July 29 reports that the effective average tax rate on R&D investments in Ireland, Lithuania, and Hungary range from -2% to -4% – suggesting . . .

Antigua and Barbuda

Antigua and Barbuda, Argentina, Russia, South Africa, and Ukraine make progress on meeting international standard on tax transparency and exchange of information in latest peer reviews: OECD→

June 24, 2021

Europe

Russian tax authorities clarify application of domestic general anti-avoidance rules

June 23, 2021

Alexey Ryabov, JTI Russia, discusses Russian tax guidance issued on March 11 establishing criteria for applying the general anti-avoidance rule under Article 54.1 of the tax code aimed at . . .

Africa

G20 draft communique reportedly endorses global minimum tax

June 22, 2021

A draft communique for the upcoming G20 finance ministers meeting on July 9–10 includes language expressing the countries’ support for a global minimum tax and new rules . . .

Europe

Finland court rejects tax authority’s transfer pricing approach to intercompany interest rates

June 17, 2021

New York City Economist Dr. Harold McClure discusses a May 21 Finnish Supreme Administrative Court decision which rejected the Finnish tax authority’s attempt to increase the intercompany interest rates charged by a Finnish financing affiliate to its Russian operating affiliate . . .

Austria

How will the European Commission define shell companies to stop tax avoidance?

June 7, 2021

New York City Economist Dr. J. Harold McClure discusses the European Commission’s launch on May 20 of an initiative to address the use of shell companies in international arrangements . . .

Europe

Russian law denounces tax treaty with Netherlands

May 27, 2021

Russian President Vladimir Putin on May 26 signed a law denouncing the treaty for the avoidance of double taxation between Russia and the Netherlands that was signed in Moscow in 1996 . . .

Americas

US support for R&D has stalled relative to France, UK, others

April 14, 2021

While several countries have significantly boosted their support for business research and development (R&D) relative to their overall economies in recent years, total US government support for business R&D . . .

Europe

Russia, Luxembourg ratify protocol increasing withholding tax rates for dividends and interest income to 15 percent: Tass→

April 1, 2021

Europe

Netherlands resisting Russian proposal to amend tax treaty to increase withholding for dividends and interest to 15 percent: TASS→

December 9, 2020

Americas

OECD reports on BEPS MLI developments for Bahrain, Chile, Indonesia, Russia, Kazakhstan

November 30, 2020

Bahrain has signed and Chile has deposited with the OECD its instrument . . .

Europe

Russia considers RUB 90 billion (USD 1.2 billion) in tax increases, hitting tobacco and tripling the mineral extraction tax except on gold, diamonds, and coal extraction but adding oil extraction: Reuters→

September 16, 2020

Cyprus

Cyprus, Russia sign tax treaty protocol increasing dividend and interest payment withholding to 15 percent: Cyprus Ministry of Finance→

September 9, 2020

Europe

Russia finance ministry plan would increase oil sector taxes by 143 billion rubles ($1.9 billion) over 2 years: Energyworld→

September 8, 2020

Europe

Russia, Malta agree to amend treaty to raise withholding tax rate for interest, dividend payments to 15 percent: Reuters→

August 19, 2020

Europe

Russia tax authority letter to guide tax and transfer pricing audits of intra-group services, shows shift to OECD approach: Noerr LLP→

August 18, 2020

Cyprus

Cyprus, Russia agree to amend tax treaty to add 15 percent withholding tax on interest and dividends

August 12, 2020

The Russian and Cyprus governments on August 10 announced that they have reached an agreement to add a protocol to their tax treaty that would . . .

Cyprus

Russia seeks to update Netherlands, Cyprus, Malta, Luxembourg tax treaty to add 15 percent withholding tax on dividends and interest: Mohammad Ali / UrduPoint→

August 10, 2020

Cyprus

Russia threatens to withdraw from Russia-Cyprus tax treaty unless Cyprus agrees to 15 percent tax on dividend payments to Cyprus parent corporations: Finanz.dk→

August 4, 2020

Americas

OECD releases reports assessing cross-border tax dispute resolution in seven countries

November 29, 2019

OECD, on November 28, released peer review reports assessing cross-border tax . . .

Africa

BRICS countries look forward to further progress on two-pillar approach to address digitalization: BRICS Information Centre→

November 18, 2019

Khaled Al Zaabi on Spanish government proposes digital services tax: “We are seeking assistance with Digital Assets and International Tax Consulting to help Abu Dhabi UAE Oil Company navigate the…” October 24 ,2024

Emma Hinson Sims on The Pillar One blueprint — the potential future of international taxation and transfer pricing: “HAPPY BIRTHDAY TO A VERY SMART, BEAUTIFUL, YOUNG LADY ON JANUARY 13TH.” January 6 ,2024

David Valdez on US Tax Court resolves Whirlpool tax dispute involving Mexican maquiladora structure: “Greetings Whirlpool Mexico, I’m trying to contact someone involved with the decision making for transportation from all of your Mexican…” October 20 ,2023

Jose Dominguez on The new US international tax rules: what you need to know about GILTI, FDII, BEAT etc.: “Very informative article. Question. Do you have a software to compute these US International Calcs to make them in house?” April 12 ,2023

Ciro César Soriano de Oliveira on Danish High Court rules on beneficial ownership of dividends for tax purposes: “Dear Ms Susi, This article is immensely clarifying. I’d like to know whether Danish Supreme Court has already granted its…” March 24 ,2023

May 19 – 20	Tax Council Policy Institute Conference	Washington, D.C.
May 19 – 20	IFA Second European Region Conference	Milan, Italy
May 24	IFA Webinar Series Pillar Two: An Update	Virtual Event
Sept. 4 – 8	IFA Congress	Berlin

Russia

US Senate Finance Committee Chair Ron Wyden and Senate Finance Committee Member Rob Portman release bipartisan bill to disallow foreign tax credits for companies that pay taxes to Russia, other tax benefits: United States Senate Committee on Finance→

US Internal Revenue Service has suspended tax information exchanges with Russian tax authorities in response to Russian war against Ukraine; no information has been shared since Feb. 24 invasion: David Lawder / Reuters→

EU’s ATAD 3 `unshell’ directive could be improved to freeze Russian oligarchs’ assets more efficiently by extending additional obligations, including the publication of financial statements and nexus to the register of ultimate beneficial owners: Renáta Bláhová / The Slovak Spectator→

US Senate Democrat leaders said they were `exploring legislation’ to eliminate the tax credits US companies get for paying taxes in Russia, which would put Russia on a list with Iran, North Korea, Sudan, and Syria: The Hill→

UK announces it is suspending exchange and sharing of tax information with Russia and Belarus, meaning Russia will no longer receive information under any of the UK’s agreements: exchange of information on request, common reporting standard or country-by-country reporting: Gov.uk→

US Senate Finance Committee Chair Wyden proposes to cancel preferential GILTI rate on Russian and Belarusian income, and deny foreign tax credits and deductions for taxes paid to Russia and Belarus: Ron Wyden / US Senate Commitee on Finance→

E-invoicing and interaction with transfer pricing: a Middle East and African perspective

Brazil, China, Russia MAP tax dispute resolutions could improve, peer reviews show

Russia proposes new taxes on digital services provided by foreign tech firms with aim to spur growth of domestic alternatives: Reuters→

US R&D tax incentives will be among least generous unless Congress acts, study finds

ICAP multilateral tax risk assurance program applications due September 30

Russia clarifies R&D expense accounting for tax purposes, associated reporting

Russia looking into revising tax treaties with Switzerland, Hong Kong, and Singapore, according to government official, following three other recent treaty revisions and renunciation of Dutch treaty: Fahad Shabbir / UrduPoint News→

Countries take diverse transfer pricing approaches to financial transactions, profit attributions

Russia’s new double tax treaty policy: the score is 3 to 1

Ireland, Lithuania, Hungary offer lowest tax rates for R&D, OECD study finds

Antigua and Barbuda, Argentina, Russia, South Africa, and Ukraine make progress on meeting international standard on tax transparency and exchange of information in latest peer reviews: OECD→

Russian tax authorities clarify application of domestic general anti-avoidance rules

G20 draft communique reportedly endorses global minimum tax

Finland court rejects tax authority’s transfer pricing approach to intercompany interest rates

How will the European Commission define shell companies to stop tax avoidance?

Russian law denounces tax treaty with Netherlands

US support for R&D has stalled relative to France, UK, others

Russia, Luxembourg ratify protocol increasing withholding tax rates for dividends and interest income to 15 percent: Tass→

Netherlands resisting Russian proposal to amend tax treaty to increase withholding for dividends and interest to 15 percent: TASS→

OECD reports on BEPS MLI developments for Bahrain, Chile, Indonesia, Russia, Kazakhstan

Luxembourg and Russia sign treaty raising tax on dividends, interest: Yannick Lambert / Luxembourg Times→

Synthesized text of Australia–Russia tax treaty, as modified by the MLI published: Australian Taxation Office→

Russia, Malta signed protocol to tax agreement raising withholding tax on dividends and interest to 15 percent: TASS→

Russia considers RUB 90 billion (USD 1.2 billion) in tax increases, hitting tobacco and tripling the mineral extraction tax except on gold, diamonds, and coal extraction but adding oil extraction: Reuters→

Cyprus, Russia sign tax treaty protocol increasing dividend and interest payment withholding to 15 percent: Cyprus Ministry of Finance→

Russia finance ministry plan would increase oil sector taxes by 143 billion rubles ($1.9 billion) over 2 years: Energyworld→

Russia, Malta agree to amend treaty to raise withholding tax rate for interest, dividend payments to 15 percent: Reuters→

Russia tax authority letter to guide tax and transfer pricing audits of intra-group services, shows shift to OECD approach: Noerr LLP→

Cyprus, Russia agree to amend tax treaty to add 15 percent withholding tax on interest and dividends

Russia seeks to update Netherlands, Cyprus, Malta, Luxembourg tax treaty to add 15 percent withholding tax on dividends and interest: Mohammad Ali / UrduPoint→

Russia threatens to withdraw from Russia-Cyprus tax treaty unless Cyprus agrees to 15 percent tax on dividend payments to Cyprus parent corporations: Finanz.dk→

OECD releases reports assessing cross-border tax dispute resolution in seven countries

BRICS countries look forward to further progress on two-pillar approach to address digitalization: BRICS Information Centre→