The Russian Ministry of Finance recently issued two guidance letters clarifying the inclusion of CFC profits for Russian tax purposes.
The first letter (03-12-11/3/5790) clarifies the non-inclusion of CFC profits in a consolidated tax base. According to the letter, for determining the corporate tax base for a consolidated group, the tax base is the total income received by all group members less total expense incurred. For this purpose, only income subject to tax at the standard corporate t…