Russian President Vladimir Putin on November 24 signed the “deoffshorization” law, requiring Russian companies and individuals to pay tax on undistributed controlled foreign corporation (CFC) profits.
The new law, effective January 1, also contains provisions clarifying the tax residency status of foreign legal entities, adds new rules on indirect transfers of immovable property through share transfers, and requires that a recipient of treaty benefits be the beneficial owner of the income.
Related MNE Tax article:
UPDATE (11/28/2014): The new law contains a few changes from earlier drafts, writes EY in its Russian Tax Brief, released November 27. For analysis of the changes, see EY.
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