The Organization for Economic Co-operation and Development, or the OECD approved a global response plan with the Base Erosion and Profit Shifting, or the BEPS in 2013
Tax and Legal Practice
Korpus Prava (Russia)
Syndicated credit (loan) is a financial instrument, which provides for getting loan-based funding from several persons and sharing rights, obligations and risks attributable to lending among them.
In 2015 and 2016, several cases based on pricing regulation norms were already heard by arbitration courts, however, they mainly covered either rights of local tax authorities to apply provisions of transfer legislation when proving unjustified tax advantages, or conditions of qualifying parties as interdependent.
For many years Cyprus has been and still is an almost single-option jurisdiction for international tax planning for Russian business. There are many reasons for this, starting with highly favorable tax system and ending with affordable prices for the establishment and maintenance of business of legal entities.