Russian FTS Order No. MMV-7-13/679@ dd 13 December 2016 “On approving the form and completion procedure for notices of controlled foreign companies and the format and submission procedure for electronic notices of controlled foreign companies”
Goltsblat BLP would like to remind you that the Russian Tax Code1 requires controlling persons to file a notice of controlled foreign companies (CFC) by 20 March of the year following that in which they book the income derived as CFC profits for Russian tax purposes2.
If such income should be deemed derived for income tax purposes in 2016, by 20 March 2017 the relevant controlling persons must file the CFC notice in the approved format with their local tax office.
The notice should specify, among other things, the taxpayer controlling person’s selected method for calculating CFC profits for Russian tax purposes3 and any grounds for exemption of such profits from taxation. Where CFC profits qualify for exemption under sub-clauses 1, 3-8 of Tax Code Article 25.13-1 (1), the notice must be accompanied by relevant documentary evidence.
The notice thus goes beyond just informing the Russian tax authorities of a CFC and, once filed, has serious legal implications for its controlling person.
The Goltsblat BLP Tax team will be happy to help prepare and file CFC notices in order to minimise tax risks for controlling persons required to file them.
1Article 25.14 (2) of the Russian Tax Code
2As prescribed by Chapters 23 and 25 of the Russian Tax Code
3See Russian Tax Code Article 309.1(1)
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