Anna Senchenko, LL. M.

It has been three years since the Law On Controlled Foreign Companies was adopted. The law has become an integral part of the Tax Code of the Russian Federation. Many things have changed for the past three years. In the course of adoption of amendments to the law, certain [...]

Hong Kong laws governing the taxation procedure for passive income from foreign sources were amended. Requirements for exemption from the corporate tax were supplemented by the economic substance requirement for the companies that meet the criteria specified in the law.

On July 5, 2016, the European Commission published a document-proposal with amendments to the Fourth EU Directive on the prevention of the use of the financial system for money laundering or terrorism financing purposes, known as 4AML.

The first and most noticeable part of Legal design is the form, i.e. the way the document looks. Earlier on, more attention was paid to decorating a document: complex font, beautiful thick paper, and other ‘high status’ elements. But now, in the age of digitalization, the focus has shifted [...]

On November 4, 2014, Russia has ratified the OECD Multilateral Convention on Mutual Administrative Assistance in Tax Matters. The Convention, which entered into force in the territory of the Russian Federation on July 1, 2015, provides a legal basis for all kinds of tax information exchange among its members.

On 14 February 2023, the news came out that Russia was included into one more list made by the EU. Some sources mention the grey list, some – the black one; future consequences also vary from source to source. In this article we will try to understand the shades [...]

The tax control bodies acquire more and more tools to identify and control creative taxpayers. For example, one of the most effective tools is the international automatic exchange of tax information.

In November 2014, the law on controlled foreign companies, which was the target for criticism, discussions, comments and etc., was adopted. The Ministry of Finance tried as much as possible to clarify certain urgent matters arising among taxpayers.

In 2013, the OECD developed BEPS Actions Plan, a plan against the tax base erosion and profit shifting. The main goal of this plan is to solve the problem of double non-taxation or incomplete taxation.

For years the Organisation for Economic Co-operation and Development (OECD) has advocated a policy of improved international tax co-operation between governments.

The "beneficial owner of income" institution was introduced into the Tax Code of the Russian Federation only in 2015, but has been successfully applied in other countries (including in Switzerland, Austria, Germany, the Netherlands, etc.).

Since December 2013, deoffshorization of Russian business has been one of the most popular tax topics. At the beginning of the previous year, the Ministry of Finance published a letter describing prevailing schemes of tax mitigation using advantages stipulated in agreements for double taxation.

ICO (Initial Coin Offering) is an actual emission of tokens for payment purposes by any project. In other words, a project issues its payment instrument which will be acceptable in its ecosystem.

In December 2013 in the address to the Federal Assembly the president Vladimir Putin stated that Russia needs a system of measures for “deoffshorization” of the Russian economy. According to him, some estimates evidence that 9 out of 10 transactions, including transactions with state-owned companies, are not subject to [...]

In this article you will find answers to many questions regarding residency,controlled foreign companies, and transfer pricing in Cyprus.

So far, in the Russian law tax residency of a legal entity was determined either by the place of its state registration (incorporation), or by availability of permanent establishment of the entity.

The tax advantage is defined as the reduction of the tax burden due to tax base reductions, granted tax deductions, tax benefits, application of lower tax rates, and the granted right for tax refund (credit) or tax reimbursement from the budget.

Nowadays we all live in a state of constant uncertainty, which is why it is more important than ever to separate rumors from facts, panic attacks from strategic planning, and treat everything we hear and see with a critical eye.

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.