Russia's Ministry of Finance has published Letter no. 03-03-06/1/85022 of 5 November 2019 concerning the inclusion of controlled foreign company (CFC) profits in cases where a CFC is indirectly held by a Russian resident taxpayer through other Russian resident taxpayers.
The letter notes that under Article 25.15 of the Russian Tax Code, the profits of a CFC are treated as profits received by the taxpayer recognized as the controlling person and included in their tax base, considering the co…