Russia Tax News
Treaty between Russia and Switzerland – Russia MoF clarifies effective date of Protocol and tax treatment applicable to interest payments
Treaty between Malta and Russia signed
Clarifications on deductibility of interest expenses related to loans taken to acquire shares
Treaty between Russia and Spain – Russian MoF clarifies tax treatment applicable to interest payments
Commodities subject to transfer pricing control rules
Intra-group loan agreements to be subject to transfer pricing control rules as from 1 January 2013
Treaty between Russia and Cyprus – Russian Appeal Court decided on applicability of beneficial owner and economic substance requirements
Treaty between Russia and UK – Russian MoF clarified whether partnerships may benefit from tax treaty provisions
Clarifications whether debt forgiveness represents taxable income
Treaty between Russia and Venezuela – clarifications whether the National Treasury Office of Venezuela qualifies as a governmental body for tax treaty purposes
Treaty between Russia and Ireland – clarifications on the conditions to create a PE in Russia and the procedure to allocate profits and expenses to such a PE
Maximum deductible interest coefficient remains unchanged until 31 December 2013
Treaty between Russia and Finland – Clarifications on the application of the reduced withholding tax on dividends in case of share capital increase
Supreme Arbitration Court decides that exemption is applicable to dividends distributed from profits of prior years
Treaty between Latvia and Russia enters into force
Protocol to treaty between Russia and Switzerland enters into force
Clarification regarding rules for requests made by tax authorities to banks
Treaty between Argentina and Russia enters into force
Moscow Federal Arbitration Court confirmed that a representative office may constitute a PE under certain circumstances
Clarifications for justifying the GDR holders residence for treaty purposes
Amendments to Tax Code
Amending protocol to treaty between Italy and Russia enters into force – details
Russian Supreme Arbitration Court: parent company may be held liable for taxes due by its subsidiary
Protocol to treaty between Cyprus and Russia enters into force
Protocol to treaty between Russia and Cyprus – details
Treaty between Russia and Chile enters into force
Protocol to treaty between Luxembourg and Russia – details
Treaty between Russia and the Netherlands – Russia clarifies applicability of reduced 5% withholding tax on dividends
Transfer pricing – new rules adopted
Transfer pricing – new draft law released
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