Russia's Federal Tax Service recently released Letter No. SD-4-3/4781 of 8 April 2021 concerning the determination of the profits of a controlled foreign company (CFC) where the profits include income from the revaluation and sale of securities.
The letter provides that in accordance with the provisions of paragraph 1 of Article 25.15 of the Russian Tax Code, the profit (loss) of a CFC is the amount of profit (loss) of the company, calculated in accordance with Article 309.1 of the Tax Code.…