Anna Senchenko, LL. M.

Nowadays one of the most burning issues of the tax practice is the concept of an actual right to income in international tax relations. Recently, tax authorities carried out numerous tax inspections, which revealed illegal application of international treaties in cases when foreign companies are not qualified as actual [...]

Not so long ago, changing terms of international taxation became a priority. The main objective is to prevent income siphoning to low-tax or tax-free jurisdictions by increasing the withholding tax rate in the Russian Federation.

In the last two-three decades, innovations in information technology and in financial markets have changed the way economies and financial systems function and the way businesses work.

Over the past two years, a lot of changes were made both to the legislation of jurisdictions popular for incorporation of foreign companies, and at the level of double taxation conventions.