Gorodissky & Partners updates

Regulation of audiovisual services
Gorodissky & Partners
  • IT & Internet
  • Russia
  • June 26 2018

The Audiovisual Services Law recently took effect and has introduced an innovative legal regime for the operation of streaming and video on demand services in Russia. The law has defined 'audiovisual services', imposed special obligations on audiovisual service owners and introduced penalties for non-compliance with the law.

Taxing transfers of trademark rights as contributions to charter capital
Gorodissky & Partners
  • Corporate Tax
  • Russia
  • June 01 2018

The Ministry of Finance recently issued an important clarification regarding the taxation of a foreign parent company's property rights to a trademark as a contribution to the charter capital of its Russian subsidiary. Previously, there had been ambiguity surrounding this issue due to the competing provisions of the Tax Code with regard to the procedure for imposing value added tax on contributions to a company's charter capital and transactions involving property rights to trademarks.

Changes in taxation of foreign companies that provide electronic services
Gorodissky & Partners
  • Corporate Tax
  • Russia
  • April 06 2018

A new law, which will enter into force in 2019, will introduce significant changes to the special procedure for imposing value added tax (VAT) on services provided in electronic form by foreign companies that have no branch or representative office in Russia. Foreign organisations that provide services in electronic form to Russian buyers are advised to register for tax accounting in Russia as VAT payers, as Russian counterparties will likely refuse to purchase electronic services from parties that fail to do so.

Additional tax reports required from Russian divisions of international companies
Gorodissky & Partners
  • Corporate Tax
  • Russia
  • February 02 2018

At the end of 2017, a number of amendments to the Tax Code came into force which significantly increased the scope of information and documents that Russian divisions of some international companies must submit to the tax authorities. Russian companies and foreign companies subject to taxation in Russia must now provide a notice of participation in an international group of companies and so-called 'country information'.

New tax benefits for innovative companies and marquee investors
Gorodissky & Partners
  • Corporate Tax
  • Russia
  • December 01 2017

The legislature is in the process of adopting a number of tax benefits intended to stimulate the development of innovative companies and marquee investments in Russia. A new law has expanded the list of expenses that can be excluded from taxable profits. Further, recently passed draft bills have introduced a new investment tax deduction and determined the terms for enforcing the concessionary income tax rates available to investors implementing large investment projects in certain areas.

New rules for determining legality of tax optimisation
Gorodissky & Partners
  • Corporate Tax
  • Russia
  • October 06 2017

Article 54.1 of the Tax Code recently came into force. It introduces new rules and definitions regarding legitimate tax optimisation and aims to clarify what is considered legitimate optimisation and what is considered tax evasion. Further, the new rules require the tax authorities to use a less formal approach when assessing the reasonableness of a tax benefit and strive to understand the economic intent of the relevant taxpayer's operations.

Multilateral convention on implementation of BEPS Plan signed
Gorodissky & Partners
  • Corporate Tax
  • Russia
  • August 18 2017

Russia recently signed the Multilateral Convention to Implement Tax Treaty-Related Measures to Prevent Base Erosion and Profit Shifting (BEPS), which was developed to implement Action 15 of the BEPS Plan. Ratification of the convention will be a serious step towards implementing the measures envisaged in the BEPS Plan, which will change the existing double tax treaty system and have a significant impact on the functioning of international groups of companies in Russia.

Federal Tax Service develops concept of unjustified tax benefit
Gorodissky & Partners
  • Corporate Tax
  • Russia
  • June 23 2017

The Federal Tax Service recently issued a notification entitled On Identifying the Circumstances of an Unjustified Tax Benefit, which summarises the law enforcement practice associated with assessing the validity of a tax benefit in disputes relating to bad-faith contracting parties. The notification will contribute to the reduction of companies' tax risks relating to an assessment of the validity of their tax benefit when dealing with contracting parties.

Changes to thin capitalisation rules for profit taxation purposes
Gorodissky & Partners
  • Corporate Tax
  • Russia
  • April 28 2017

Under certain conditions, a company may have a controlled indebtedness, for which the accounting of expenses for profit taxation purposes should be made according to the special rules regarding so-called 'thin capitalisation' stipulated in Article 269 of the Tax Code. Recent changes to the thin capitalisation rules aim to strengthen the barriers that prevent the outflow of capital abroad to the foreign companies of multinationals doing business in Russia.

New procedure for recognition of losses in profit taxation
Gorodissky & Partners
  • Corporate Tax
  • Russia
  • March 10 2017

The procedure for transferring previous years' losses to future tax periods for the purpose of calculating corporate income tax has changed substantially for 2017. Previously, only losses incurred during the 10 years preceding the relevant tax period could be recognised consecutively. As of January 1 2017, the procedure for carrying losses forward has changed and the 10-year limitation on the carrying forward of losses has been abolished.

Tax aspects of cost contribution agreements within MNE groups
Gorodissky & Partners
  • Corporate Tax
  • Russia
  • December 23 2016

During 2015 and 2016 the dispute between taxpayers and the tax authorities regarding the exclusion of multinational enterprise groups' Russian subsidiaries from the requirement to pay corporate income tax on so-called 'intra-group expenses' came under scrutiny. The Russian courts have traditionally treated the actions by affiliated companies in this regard liberally. However, in 2016 Russian court practice began to change in favour of the tax authorities.

Google tax revolutionises tax regime for digital content sales
Gorodissky & Partners
  • Corporate Tax
  • Russia
  • July 22 2016

The State Duma of the Federal Assembly recently passed a new law introducing significant changes to the taxation of foreign companies selling software and internet services in the Russian territory. The so-called 'Google tax' will require foreign companies providing services in electronic form and selling content online to Russian consumers to register with the Russian tax authorities from January 1 2017.

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