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In 2015, Russia introduced several amendments to its tax rules aimed at preventing profit shifting of Russian profits to preferential tax jurisdictions and at re-routing funds back to Russia (deoffshorisation law). The Russian deoffshorisation law, and more specifically the introduction of Controlled Foreign Companies (CFC) rules, requires Russian tax residents to disclose any relevant information on their foreign holding structures, meaning both foreign companies and non-corporate structures. Typically, foreign holding structures were and are still used by Russian beneficiaries for confidentiality reasons and to reduce (or even to evade) Russian taxes. A typical holding structure controlled by Russian beneficiaries would include Russian-based operating companies held by a Cypriot, Dutch or other foreign holding company which, in turn, is held by one or a chain of companies (usually incorporated in low tax jurisdictions). Such companies are usually treated as CFC for their beneficiaries. The new disclosure obligations with respect to such structures effectively eliminate the tax effects of their use, as the profits of Russian CFC are now to be taxed in Russia. Nevertheless, we cannot say that this has led to the mass liquidation of foreign structures. Many Russian businesses are still using the existing structures, and in many cases do not disclose information about them in accordance with the new rules.
What does this mean for foreign investors that plan to acquire an interest in Russian businesses?
Please download the full articel about Russian deoffshorisation law.