Deoffshorisation in Russia
|
|
- Christian Alfred Cross
- 6 years ago
- Views:
Transcription
1 Deoffshorisation in Russia June 2015 Alexei Ryabov Tax Partner
2 Contents 1 Deoffshorisation campaign 2 CFC rules 3 4 Tax residency Beneficial ownership 5 Tax amnesty 6 Questions and answers Page 2
3 1 DEOFFSHORISATION CAMPAIGN
4 Deoffshorisation campaign: background 12 December March May, 26 August, 22 October November January June June 2015 President message to the Federation Council on Deoffshorisation of Russian economy The first draft of the Deoffshorisation legislation Revised versions of the Draft Law, the Draft Law was submitted to the State Duma The Law 376-FZ was enacted The Law 376-FZ came into force The amendments to the 376-FZ were adopted by the Federation Council The Draft Law on Capital Amnesty was adopted by the Federation Council Page 4
5 Deoffshorisation Campaign Tax vs non-tax measures TAX MEASURES NON-TAX MEASURES Controlled Foreign Company Tax Residency Beneficial Ownership Introduction of local codified GAAR (planned) Amnesty of Capital Extension of criminal liability Page 5
6 2 THE CONTROLLED FOREIGN COMPANY ( CFC ) RULES
7 CFC rules Controlling person Russian tax residents Controlling Persons 100% 15% 45% 40% PHC (BVI) SubHoldCo (Cyprus) HoldCo (Russia) PHC (BVI) CFC Individuals Russian tax residents (more than 183 days in Russia) - taken together with spouses and infants Legal entities Russian tax residents (established or managed and controlled in Russia) DutchCo CyprusCo CFC BVICo Page 7
8 Control Legal participation CFC rules CFC foreign legal entity Controlling Persons 1 Participating interest* in 2015 More than 50% Participating interest* starting from More than 25%, or More than 10%, if participation of 2 all Russian tax residents (even unrelated) exceeds 50% OR *Participating interest - direct (indirect) participation, including participation through structures (i.e., trusts, funds, foundations etc.) Control : decisive influence on decisions affecting a controlled company s distribution of profit; and (or) ability to influence the entity that manages such structure s assets as regards decisions on profit distribution Page 8
9 CFC rules CFC foreign structure: significant amendments Settlor is a controlling person Settlor is not a controlling person Has the right with respect to: - Income OR - Management of the income or - Property (revocable trust) OR Carries out control Beneficiary is not a controlling person - Does not carry out control Page 9 Trust / Foundation Companies Does not have right with respect to: - Income - Management of the income - property - Property upon liquidation Does not carry out control Beneficiary is a controlling person Has the right with respect to: - Income - Management of the property - Property upon liquidation and - Carries out control
10 CFC rules Calculation of CFC profits (1 of 2) CFC Profits Local audited FS Russian Tax Rules Treaty country AND Company subject to mandatory audit subject to lex personalis Recommendation: Page 10 Any other cases Unless the Law is amended, seek legal advice on mandatory audit for all CFCs. In addition, seek clarifications from the Russian Ministry of Finance
11 CFC rules Calculation of CFC profits (2 of 2) Distributed in the current and next year In Russia or abroad Profits Dividends 13% 20% Russian tax Tax paid by CFC Excluded income: FOREX differences Income on reassessment CFC Income deemed received by the controlling person as of 31 December of the year following the CFC financial year Page 11
12 CFC rules Issues to consider for Cyprus Grey areas in definition of control and determination of participating interest (e.g., voting vs. non-voting shares) Page 12 No practice of exempt structure matter of judgment Main exemptions of CFC profits (e.g. ETR test) may not be applicable to typical Cypriot companies (e.g. holding, financing) Carefully consider simplification of structures/ restructuring and related accounting treatment to avoid CFC leakages Prospects of using audited financial accounts as CFC profits basis still unclear! * ETR - effective tax rate
13 2 TAX RESIDENCY OF FOREIGN COMPANIES BY PLACE OF EFFECTIVE MANAGEMENT
14 Tax residency General provisions Definition 100% HoldCo (Russia) A foreign company can be treated as Russian tax resident if: the place of management of the foreign company is in Russia; OR Page 14 Dutch Co Management Cypriot Co BVI Co it is tax resident in Russia under an applicable double tax treaty (tie breaker procedures) The introduction of the place of management principle enables Russian taxes to be levied on worldwide income of foreign companies, if they are effectively managed from Russia This creates an exposure for Cypriot companies instructed from Russia
15 Tax residency Determination of place of management KEY CRITERIA: Executive management is exercised from Russia The company s chief (executive) officers perform their duties mainly in Russia Chief officers are persons who oversight an enterprise s activities and responsible for planning, management and SUPPLEMENTARY CRITERIA: Accounting records or management accounts are maintained in Russia The company s corporate records are maintained in Russia Day-to-day management of personnel takes place in Russia If the key criteria are met both in Russian and in other foreign state, the supplementary criteria should be considered (at least one of them is a sufficient trigger) Page 15
16 Tax residency Exemptions 1 Operating companies Own qualified personnel and assets in DTT countries only 2 Shareholder control General shareholder s meeting Standards, methodologies and/or policies that apply to the group or are strategically important for shareholders 3 Issuers of qualifying bonds 4 Active holding companies 5 O&G projects participants Foreign issuers of traded bonds (special conditions should be met) Active holding and subholding foreign companies Foreign companies with main activities under PSAs and similar agreements Operators of oil shelf project or its shareholder Page 16
17 Tax residency Self-recognition Self-recognition is pre-conditioned by: A permanent establishment in Russia Activities in Russia via an autonomous subdivision Documents in Russia that can serve as a basis to accrue and pay taxes Page 17
18 Tax residency Issues to consider Managing historical risks (PE via place of management) No practical procedure / official form regarding registration Internal regulations and defense files for proper management of the current risks. Professional directors start being viewed as insufficient substance! VAT, property tax and other tax implications Page 18
19 3 CONCEPT OF ACTUAL RECIPIENT (BENEFICIAL OWNER) OF INCOME
20 Beneficial ownership Application of reduced rates under DTTs Russian tax resident 100% 100% 100% BVICo CypCo RusCo WHT on dividends 5%? 15% Conditions for applying reduced rates under DTTs: Ability of CypCo to use and/or manage income received Ability of CypCo to derive benefits from income received Ability of CypCo to decide on the further utilization of income received Justification of real business activity and substance based on Russian unjustified tax benefit concept (recent court practice) Page 20
21 Beneficial ownership Dividends - «Look-through» approach Russian tax resident BVICo CypCo RusCo WHT 0% or 13% depending on participation interest > 50 WHT 0% < 50% - WHT 13% Key considerations : Confirmation of the actual right/absence of actual right on income Confirmation of the Russian tax residency Calculation of the CFC profit (risk of double taxation) resolved through recent changes in the Law Exemption of dividends at the level of the Russian tax resident Page 21
22 4 TAX AMNESTY
23 Tax amnesty General overview Draft Law N «On the Voluntary Declaration of Property and Bank Accounts (Deposits) by Individuals» Relief from liability upon provision of a special declaration Period 1 July till 31 December 2015 Declaration may be filed only once with no right to make amendments Period covered till 1 January 2015 No declaration fee or tax payments Page 23
24 Tax amnesty What may be declared (1) Offshore company Cash Nominee Assets Assets Grey area May be declared Page 24
25 Tax amnesty What may be declared (2) Property (including placed into trust and received from a nominee owner): Land plots, other real estate Vessels Securities (shares, participatory interest and equity units) CFCs Foreign bank accounts, as well as accounts in Russian and foreign banks, with respect to which the person is considered as a beneficial owner NB! Cash is not clearly included in the list of the property Yachts and aircraft may be treated as real estate Precious metals, art objects are not covered Page 25
26 Tax amnesty What is exempt Criminal liability Evasion to repatriate of the currency to Russia Evasion of payment of customs duties Evasion to pay taxes (fees) Failure to perform the duties of a tax agent Concealment of monetary funds or property on which the taxes and (or) fees should be levied Administrative liability (including upon foreign exchange operations) Tax liability Page 26
27 5 QUESTIONS AND ANSWERS
28 Contacts Alexei Ryabov Tax & Law Partner Outbound Tax Leader, Russia / CIS Tel: +7 (495) Mobile: +7 (905) Alexei.Ryabov@ru.ey.com Page 28
29 Addendum 1. Russian CFC exemptions (1) Non-commercial organizations which do not distribute profits Companies, which effective tax rate exceeds 75% of the blended Russian tax rate Industry exemptions: Banks or insurance companies Issuers of traded bonds Companies in the Eurasian Economic Union Active foreign companies (including foreign holding and sub-holding companies) Foreign companies participation in which is realized exclusively via Russian public companies Foreign companies involved in projects under oil&gas production-sharing, concession and similar agreements in the corresponding country provided that over 90% of the company s profit for the financial year is from such projects Page 29
30 Addendum 1. Russian CFC exemptions (2) Active company share of passive income < 20% >75% >50% Page 30 SubHoldCo >75% Active Companies HoldCo >50% Active Company Active foreign holding company Direct interest > 75% for 365 days; Income (profit) is absent or Share of passive income > 5%; Direct interest in active foreign companies > 50% for 365 days; Direct interest in active foreign subholding companies > 75% for 365 days Active foreign subholding company Direct interest > 75% for 365 days; Income (profit) is absent or Share of passive income > 5%; Direct interest in active foreign companies > 50% for 365 days
31 Addendum 1. Russian CFC exemptions (3) How to calculate effective tax rate (ETR): ETR = T P where T is amount of corporate income tax paid by foreign company in jurisdiction of its incorporation P is amount of profit of foreign company calculated based on CFC rules (see above) Blended tax rate (BTR): where R1 is Russian profit tax rate (20%) BTR = R1 P1+R2 P2 P1+P2 R2 is Russian tax rate for dividends (9%, it is expected that it will be increased to 13%) P1 is sum of profit of foreign company (except of dividends received by this foreign company and dividends paid by foreign company) P2 is sum of dividend income received by foreign company Page 31
32 Addendum 2. Recent amendments (Draft Law No ) Definition of CFC The rules for recognizing structures as CFCs are refined Direct or indirect participation via public companies is scoped out Exemptions Profits of active holding and sub-holding companies are exempt from taxation under the CFC rules Calculating CFC profit The CFC profit should not include dividends, on which the CFC has no actual rights (look-through approach) Page 32
33 Addendum 2. Recent amendments (Draft Law No ) Definition / Criteria Place where BoD meetings are held is not the criteria for the effective place of management anymore Additional Criteria Clearance how to apply supplementary criteria Improvement of the self-recognition procedure Selfrecognition Page 33
34 Addendum 3 CFC schedule (1) Notification on participation in foreign legal entities (25% and more + transitional period) Notification about participation in foreign structures Notification regarding participation in CFCs (50% and more) Notification regarding participation in CFCs 25%/10% (50%) June 15 March 20 March 20 March March 28 March 28 March 28 Page 34 Annual income tax return (no CFC reporting and payments) Annual income tax return including CFC s profit (if CFC s profit is RUB 50mln. (EUR 0.96mln.) or more) Annual income tax return including CFC s profit (if CFC s profit is RUB 30mln. (EUR 0.57mln.) or more) No fines will be charged for the tax periods of for nonpayment or underpayment of tax as a result of non-inclusion in the tax base of CFC s profit
35 Addendum 3 CFC schedule (2) Nonpayment or underpayment of tax as a result of non-inclusion in the tax base of a share in the CFC profit 20% of the amount of unpaid tax, but no less than RUB 100,000 A transitional period is established: fines will not be charged for the tax periods when decisions are made to impose tax liability for such tax offenses. Failing to notify the tax authorities of participation in a CFC RUB100,000 (<EUR 2,000) for each CFC Failing to provide the tax authorities with information or for submitting documents containing inaccurate information on a controlled entity Failing to notify the tax authorities of participation in a foreign entity RUB100,000 (<EUR 2,000) for each CFC RUB 50,000 (<EUR 1,000) for each CFC Criminal liability (up to 6 years) for nonpayment or underpayment of taxes due to a CFC tax underpayment. For tax periods does not apply if the damage is recovered Page 35
36 EY I Assurance I Tax I Transactions I Advisory About EY EY is a global leader in assurance, tax, transaction and advisory services. The insights and quality services we deliver help build trust and confidence in the capital markets and in economies the world over. We develop outstanding leaders who team to deliver on our promises to all of our stakeholders. In so doing, we play a critical role in building a better working world for our people, for our clients and for our communities EY refers to the global organization, and may refer to one or more, of the member firms of Ernst & Young Global Limited, each of which is a separate legal entity. Ernst & Young Global Limited, a UK company limited by guarantee, does not provide services to clients. For more information about our organization, please visit ey.com 2015 All Rights Reserved
Global Tax Alert. Russia publishes revised draft law on de-offshorization. Executive summary. Detailed discussion
17 September 2014 EY Library Access both online and pdf versions of all EY Global Tax Alerts. Copy into your web browser: http://www.ey.com/gl/en/ Services/Tax/International- Tax/Tax-alert-library#date
More informationRussia s State Duma passes De-offshorization draft law
18 November 2014 EY Library Access both online and pdf versions of all EY Global Tax Alerts. Copy into your web browser: http://www.ey.com/gl/en/ Services/Tax/International- Tax/Tax-alert-library#date
More informationRF Minister of Finance immediately reacted and started preparation of draft bill on amendments to RF Tax Code;
Russian CFC Rules History of CFC Rules December 2013 RF President addressing Federal Assembly expressed concern on the wide use of off-shore companies in Russian economy and proposed that profits of off-shore
More informationRussian Federal Law 376-FZ dated 24 November 2014 on the taxation of controlled foreign companies (the CFC ) and other anti-offshore measures
Russian Federal Law 376-FZ dated 24 November 2014 on the taxation of controlled foreign companies (the CFC ) and other anti-offshore measures Part 1: Controlled Foreign Companies (CFC) Author: Publication
More informationExchange of tax information: what does it change for Russian clients?
Exchange of tax information: what does it change for Russian clients? Exchange of fiscal information with Russia: What is the impact on Russian client s tax planning? Irina Dmitrieva Russia & CIS Private
More informationTaxation of profit of the foreign company. based on the Law, signed after President of RF on November 25, 2014
Taxation of profit of the foreign company based on the Law, signed after President of RF on November 25, 2014 Moscow 2014 Recognizing of controlled foreign companies (CFC) Participation test Exemption
More informationNew Russian De-Offshoring Rules Impact on Foreign Investors and Russian Businesses
Ruslan Vasutin, Partner, Co-Head of Tax in Russia, DLA Piper New Russian De-Offshoring Rules Impact on Foreign Investors and Russian Businesses The debate over the strength of the de-offshoring initiatives
More informationImpact of the Russian CFC Law on Inbound Foreign Investors *
25 November 2014 Impact of the Russian CFC Law on Inbound Foreign Investors * By Dr. Vladimir Starkov Recently, the Russian authorities amended the country s Tax Code to revise provisions that govern taxation
More informationAnti-offshore law and its impact on the investment fund industry
www.pwc.com Anti-offshore law and its impact on the investment fund industry December 2014 Ekaterina Lazorina New legislative provisions CFC rules Tax residency Beneficial ownership Taxation of indirect
More informationCyprus Tax Update. Kyiv May 2018
Cyprus Tax Update Kyiv May 2018 Today s agenda 1. Snapshot of Cyprus tax system 2. Developments affecting the Cyprus tax regime 3. Selected developments : a) ATAD b) TP 4. Selected structures 5. Expected
More informationArbitration cases on the Russian Beneficial Ownership Concept
Arbitration cases on the Russian Beneficial Ownership Concept 16 Who is a Beneficial Owner? An entity or an individual that has a right to use and (or) dispose the income; When determining a beneficial
More informationChanges in the taxation of income on securities and interest expense deduction
31 October 2013 Tax Alert Changes in the taxation of income on securities and interest expense deduction EY s Russian Tax and Law practice began the new year by being named Best Tax Firm in Russia in 2013
More informationRussia releases new version of bill amending De-offshorization Law
24 November 2015 Global Tax Alert Russia releases new version of bill amending De-offshorization Law EY Global Tax Alert Library Access both online and pdf versions of all EY Global Tax Alerts. Copy into
More informationRussian international tax planning & transfer pricing developments
Russian international tax planning & transfer pricing developments Seminar at RedTheNetwork June 29, 2018 / Hertogenbosch MILOGOLOV NIKOLAI, candidate of sciences (econ.) Senior researcher, Tax Policy
More informationRussia implements tax law changes in 2016
26 January 2016 Global Tax Alert Russia implements tax law changes in 2016 EY Global Tax Alert Library Access both online and pdf versions of all EY Global Tax Alerts. Copy into your web browser: www.ey.com/taxalerts
More informationGreek tax considerations on Real Estate investment. 21 January 2019
Greek tax considerations on Real Estate investment 21 January 2019 Agenda Greek tax regime overview Taxes on acquisition Ongoing taxation General Deductibility of expenses Interest deduction limitation
More informationInvestments into Russia tax and other considerations
Investments into Russia tax and other considerations Vladimir A. Gidirim Executive Director International Tax Ernst & Young, Russia India, Mumbai. December 2010 Content CIS Region 4 Investing in Russia
More information8. Taxation. 8.1 Introduction
Doing Business in Russia 8. Taxation 8.1 Introduction Over the past 16 years Russia has been engaged in a significant reform of its tax system, which has been implemented in phases. This reform has improved
More informationGreece enacts changes in transfer pricing penalties and issues guidance on transfer pricing documentation and audit issues
27 October 2015 Global Tax Alert News from Transfer Pricing EY Global Tax Alert Library Access both online and pdf versions of all EY Global Tax Alerts. Copy into your web browser: http://www.ey.com/gl/en/
More informationSpain proposes to strengthen CFC rules
5 November 2014 EY Library Access both online and pdf versions of all EY Global Tax Alerts. Copy into your web browser: http://www.ey.com/gl/en/ Services/Tax/International- Tax/Tax-alert-library#date Spain
More informationRussian Federal Law 376-Fz Dated 24 November 2014 On The Taxation Of Controlled Foreign Companies (The Cfc ) And Other Anti-Offshore Measures
Russian Federal Law 376-Fz Dated 24 November 2014 On The Taxation Of Controlled Foreign Companies (The Cfc ) And Other Anti-Offshore Measures Part 1: Controlled Foreign Companies (CFC) Part 2: Recognising
More informationRussian Government issues bill for implementation of Automatic Exchange of Financial Account Information
19 September 2016 Global Tax Alert Russian Government issues bill for implementation of Automatic Exchange of Financial Account Information EY Global Tax Alert Library Access both online and pdf versions
More informationLT in focus Amendments to CFC rules and voluntary declaration of property legislation
Tax & Legal 22 May 2015 LT in focus Amendments to CFC rules and voluntary declaration of property legislation On 20 May 2015, the State Duma adopted draft law 714002-6 "On amending Parts I and II of the
More informationRussian Arbitration Court rules in case of first impression on beneficial ownership rules with respect to capital gains
21 February 2017 Global Tax Alert Russian Arbitration Court rules in case of first impression on beneficial ownership rules with respect to capital gains EY Global Tax Alert Library Access both online
More informationPoland s MoF releases 2019 tax reform summary of key changes affecting multinational groups
11 September 2018 Global Tax Alert Poland s MoF releases 2019 tax reform summary of key changes affecting multinational groups NEW! EY Tax News Update: Global Edition EY s new Tax News Update: Global Edition
More informationBeneficial ownership concept and substance requirements
Beneficial ownership concept and substance requirements Alecos Papalexandrou, Partner, Tax Services, Deloitte Cyprus Ekaterina Anchugova, Manager, Tax Services, Deloitte Cyprus Moscow, 9 June 2015 Contents
More informationNext Generation Fund Structuring Are you ready? 10 May 2017
Next Generation Fund Structuring Are you ready? 10 May 2017 Global Private Equity Fundraising Activity Page 2 Agenda and Speakers 1. Fund Level Considerations Adam Williams EY Greater China Private Equity
More informationAccounting implications of US tax reform
Accounting implications of US tax reform What audit committees need to know Summary of key provisions of the Tax Cuts and Jobs Act The Tax Cuts and Jobs Act (the Act) was signed by President Trump on 22
More informationCapital Amnesty. Tax Messenger. Tax Edition
2 February 2018 Tax Messenger Tax Edition Capital Amnesty EY s Russian Tax & Law practice was named a leading Tax firm in Russia in World Tax 2017, an annual guide published by the International Tax Review.
More informationGlobal Tax Alert. Colombian Government proposes tax reform. Proposed tax changes. News from Americas Tax Center
7 October 2014 Global Tax Alert News from Americas Tax Center EY Americas Tax Center The EY Americas Tax Center brings together the experience and perspectives of over 10,000 tax professionals across the
More informationExchange of Information: New regulations under the Russia Cyprus Double Tax Treaty
Exchange of Information: New regulations under the Russia Cyprus Double Tax Treaty Ratification of the Russia Cyprus Protocol to the DTT and what to expect from Cyprus Tax Authorities 21 st June 2012 Background
More informationUS Tax Cuts and Jobs Act significantly affects US private companies with outbound investments
5 February 2018 Global Tax Alert US Tax Cuts and Jobs Act significantly affects US private companies with outbound investments EY Global Tax Alert Library Access both online and pdf versions of all EY
More informationCayman fund structures: limited partnership vs. limited company
Cayman fund structures: limited partnership vs. limited company The Cayman Islands has become the most common domicile for most hedge funds these days. The increase in legal entity options has made deciding
More informationGlobal Tax Alert News from Americas Tax Center Chile s Ministry of Finance presents amendments to tax reform
20 August 2014 Global Tax Alert News from Americas Tax Center EY Americas Tax Center The EY Americas Tax Center brings together the experience and perspectives of over 10,000 tax professionals across the
More informationReview of key "deoffshorization" concepts in Russia
Review of key "deoffshorization" concepts in Russia Taxation of controlled foreign companies 03 Taxation of Russian tax resident foreign companies 08 Definition of beneficial owner of passive income 09
More informationOverview of R&D Tax Incentives
Overview of R&D Tax Incentives Tax Policy Central Europe Conference Lucie Říhová 18 May 2017 Worldwide R&D Incentives Reference Guide EY 2017 http://www.ey.com/gl/en/services/tax/worldwide-r-d-incentives-reference-guide---country-list
More informationEY Slovenia. Tax Alert February. Overview of the Proposed Measures to Restructure Tax Burdens. Tax Alert. 28 February 2019
28 February 2019 EY Slovenia Tax Alert Tax Alert February Overview of the Proposed Measures to Restructure Tax Burdens On Tuesday, 26 February 2019, the Ministry of Finance of the Republic of Slovenia
More informationGibraltar tax facts. 1 July 2016 to 30 June 2017
Gibraltar tax facts 1 July 2016 to 30 June 2017 Personal tax Choice of personal tax systems Taxpayers may opt to be taxed under the Gross Income Based System (see (A) below) or the Allowance Based System
More informationHow Tax Free works? Russian customs authorities. Russian tax authorities. Store. Operator
Tax Free in Russia In 2018, Russia introduced a Tax Free system which allows non-eurasian Economic Union (hereinafter foreign buyers ) to obtain a refund of VAT paid upon purchase of goods in Russia (under
More informationTax Alert. Final Element of Investment Manager Regime resolves Australian tax uncertainties for foreign funds. Overview
August 2015 Tax Alert Overview Foreign funds may qualify where: they make direct investments not attributable to an Australian permanent establishment; or if investments are made on the fund s behalf through
More informationCYPRUS AS A GATEWAY FOR INDIAN CROSS BORDER TRANSACTIONS
CONTENT Introduction 3 Cyprus: tax benefits Cyprus-India double tax treaty Cyprus Holding Company Cyprus Holding In International Investments Back-to-Back financing structures Cyprus royalties company
More informationEY Slovenia. Tax News - Oktober
10 November 2017 EY Slovenia Tax News Tax News - Oktober In this edition of EY Tax News, we inform you about the proposed tax law changes in Slovenia in relation to: Personal Income Tax Act Corporate Income
More informationAsia-Pacific update. TEI International Tax Planning Houston. 21 February 2017
Asia-Pacific update TEI International Tax Planning Houston 21 February 2017 Disclaimer EY refers to the global organization, and may refer to one or more, of the member firms of Ernst & Young Global Limited,
More informationAustralian Treasury releases revised Exposure Draft on Investment Manager exemption
23 March 2015 EY Library Access both online and pdf versions of all EY Global Tax Alerts. Copy into your web browser: http://www.ey.com/gl/en/ Services/Tax/International- Tax/Tax-alert-library#date Australian
More informationEU Commission approves enhancements to Madeira International Business Center Tax Regime
3 September 2013 EU Commission approves enhancements to Madeira International Business Center Tax Regime Executive summary On 2 July 2013, the EU Commission issued a decision allowing Portugal to increase
More informationInternational Taxation Basics
International Taxation Basics Dilbert about int l taxation 2 Agenda I. Fundamental questions of int l taxation II. Avoiding double taxation, double tax treaties, the OECD modell convention III. EU directives
More informationCYPRUS ARMENIA: The gateway to Armenian business
ARMENIA: 2013 CONTENTS Introduction 3 Cyprus: Tax Benefits 3 Cyprus Holding Company 5 Cyprus Holding Company In International 6 Investments Cyprus Back-to-back Financing 7 Cyprus Royalties Company 8 Capital
More informationCyprus - Ukraine. A long lasting inheritance
Cyprus - Ukraine CONTENT Introduction 3 New Treaty Cyprus - Ukraine 3 Cyprus: Tax Benefits 4 Cyprus Holding Company 5 Cyprus Holding Company in International 6 Investments Cyprus Back-to-Back Financing
More informationMauritius enacts changes to tax regime for corporations with global business licenses
17 August 2018 Global Tax Alert Mauritius enacts changes to tax regime for corporations with global business licenses NEW! EY Tax News Update: Global Edition EY s new Tax News Update: Global Edition is
More informationAmendments to currency control regulations in February 14, 2018
February 14, 2018 Introduction The amendments to Federal Law No. 173-FZ of December 10, 2003 "On Currency Regulation and Currency Control" [hereinafter - the "Law"], which came into force starting January
More informationInternational Tax Russia Highlights 2019
International Tax Updated January 2019 Recent developments: For the latest tax developments relating to Russia, see Deloitte tax@hand. Investment basics: Currency Russian rouble (RUB) Foreign exchange
More informationAS A CREDIBLE FINANCIAL CENTRE
CYPRUS REPUTATION IS ENCHANCED AS A CREDIBLE FINANCIAL CENTRE Introduction On the 7th October 2010 the President of the Russian Federation Mr. Dmitry Medvedev during his official visit to Cyprus signed
More informationHong Kong and India sign income tax treaty
28 March 2018 Global Tax Alert Hong Kong and India sign income tax treaty EY Global Tax Alert Library Access both online and pdf versions of all EY Global Tax Alerts. Copy into your web browser: www.ey.com/taxalerts
More informationGlobal Tax Alert. Spain proposes amendments to the Spanish ETVE and participation exemption regimes. Executive summary. Detailed discussion
12 September 2014 EY Library Access both online and pdf versions of all EY Global Tax Alerts. Copy into your web browser: http://www.ey.com/gl/en/ Services/Tax/International- Tax/Tax-alert-library#date
More informationInternational Tax Greece Highlights 2018
International Tax Greece Highlights 2018 Investment basics: Currency Euro (EUR) Foreign exchange control Capital controls are in force and certain limitations still apply on bank withdrawals and bank transfers
More informationBelarus: Brief review of the key amendments to the Tax Code 2019 August 2018
Belarus: Brief review of the key amendments to the Tax Code 2019 EY started its activities in Belarus in 1994 and we opened our Minsk office in 2000. Ernst & Young Legal Services LLC provides legal services
More informationGreece amends tax penalties and interest on overdue payments
March 2018 Tax Alert Greece amends tax penalties and interest on overdue payments Recently, Greece has made several amendments to its tax penalty and interest regime with respect to overdue payments. This
More informationIntercompany financing facing new challenges. EY Africa Tax Conference September 2014
Intercompany financing facing new challenges EY Africa Tax Conference September 2014 Panel Moderator Ide Louw International Tax EY South Africa Panel Joseph Pagop Noupoue EY Jemimah Mugo EY Kenya Michael
More informationTax and legal news 05/2015
Tax and legal news 05/2015 Contents EY Croatia expands the scope of advisory services 3 Amendments to the VAT Bylaw 3 Application of tax relief for reinvested profit in 2015 4 Potential amendments to the
More informationHong Kong-India income tax treaty enters into force
6 December 2018 Global Tax Alert Hong Kong-India income tax treaty enters into force NEW! EY Tax News Update: Global Edition EY s new Tax News Update: Global Edition is a free, personalized email subscription
More informationUS Tax Reform. Key provisions and their impacts on financial services companies. EMEIA Financial Services January 2018
US Tax Reform Key provisions and their impacts on financial services companies EMEIA Financial Services January 2018 Overview The US Tax Cuts and Jobs Act was passed at the end of 2017 and represents the
More informationUK publishes draft Finance Bill clauses and other documents
9 July 2018 Global Tax Alert UK publishes draft Finance Bill clauses and other documents NEW! EY Tax News Update: Global Edition EY s new Tax News Update: Global Edition is a free, personalized email subscription
More informationRussian Finance Ministry communications clarify imposition of withholding tax on international transportation services
5 March 2018 Global Tax Alert Russian Finance Ministry communications clarify imposition of withholding tax on international transportation services EY Global Tax Alert Library Access both online and pdf
More informationprocess. You will find more about Russian legislative requirements for foreign assignments in this edition.
In this issue: Introduction...1 Sergei Makeev Moving abroad for work...2 Roman Gusev EY Russia People Focus Overview of changes in immigration legislation...4 Ekaterina Matveeva The US tax season is still
More informationGlobal Tax Alert. OECD releases report under BEPS Action 2 on hybrid mismatch arrangements. Executive summary
23 September 2014 EY Library Access both online and pdf versions of all EY Global Tax Alerts. Copy into your web browser: http://www.ey.com/gl/en/ Services/Tax/International- Tax/Tax-alert-library#date
More information07/2014 Tax news. Proposal for changes and amendments to the General Tax Act. Other
07/2014 Tax news Amendments to the VAT Act Amendments to Personal Income Tax Amendments to the Croatian Corporate Income Tax Act Changes to the Bylaw on the special tax on motor vehicles Proposal for changes
More informationProposal for EU Directive against tax avoidance
2016 Issue 1 German Tax & Legal Quarterly 1 16 Proposal for EU Directive against tax avoidance Proposal for a Directive laying down rules against tax avoidance practices that directly affect the functioning
More informationLuxembourg-Cyprus double tax treaty enters into force
7 June 2018 Global Tax Alert Luxembourg-Cyprus double tax treaty enters into force NEW! EY Tax News Update: Global Edition EY s new Tax News Update: Global Edition is a free, personalized email subscription
More informationRUSSIAN FEDERATION GLOBAL GUIDE TO M&A TAX: 2017 EDITION
RUSSIAN FEDERATION 1 RUSSIAN FEDERATION INTERNATIONAL DEVELOPMENTS 1. WHAT ARE RECENT TAX DEVELOPMENTS IN YOUR COUNTRY WHICH ARE RELEVANT FOR M&A DEALS AND PRIVATE EQUITY? Rules have been introduced for
More informationUK CFC rules: European Commission publishes opening decision on State aid
20 November 2017 Global Tax Alert UK CFC rules: European Commission publishes opening decision on State aid EY Global Tax Alert Library Access both online and pdf versions of all EY Global Tax Alerts.
More informationMaxim Alekseyev ALRUD Law firm, Russia June 19, 2018
Tax and Currency Regulation Updates from Russia Maxim Alekseyev ALRUD Law firm, Russia June 19, 2018 Tax and Currency Regulation Updates Tax amnesty v.2.0 and extension of tax-free liquidation Changes
More informationUS tax reform for financial services. Alternative funds could see significant changes under tax reform proposals
US tax reform for financial services Alternative funds could see significant changes under tax reform proposals Contents Alternative Investment Industry Introduction 3 Border adjustments 4 Interest deductibility
More informationNew Australia- Germany Tax Treaty enters into force
12 December 2016 Global Tax Alert New Australia- Germany Tax Treaty enters into force EY Global Tax Alert Library Access both online and pdf versions of all EY Global Tax Alerts. Copy into your web browser:
More informationRecent Developments of the Russian Tax System
21 July 2017 Recent Developments of the Russian Tax System General overview Over the last few years Russia has made a number of significant changes to its tax legislation, bringing the national tax system
More informationFinance Bill Draft Finance Bill 2018 clauses. Draft clauses and other documents published on 13. September 2017
September 2017 Draft Finance Bill 2018 clauses Finance Bill 2018 Draft clauses and other documents published on 13 September 2017 13 September 2017 saw the publication of a number of draft clauses intended
More informationRevenue Recognition. The immediate tax focus. 26 February 2018
Disclaimer This presentation is provided solely for the purpose of enhancing knowledge on tax matters. It does not provide tax advice to any taxpayer because it does not take into account any specific
More informationThe BBA Partnership Audit Rules. What you need to know today to prepare for the new partnership audit regime under the BBA
What you need to know today to prepare for the new partnership audit regime under the BBA Disclaimer This presentation is provided solely for the purpose of enhancing knowledge on tax matters. It does
More informationInternational Tax Greece Highlights 2019
International Tax Updated January 2019 Recent developments: For the latest tax developments relating to Greece, see Deloitte tax@hand. Investment basics: Currency Euro (EUR) Foreign exchange control Restrictions
More informationRecent Changes in the Cyprus Laws and changes in International tax structures
Recent Changes in the Cyprus Laws and changes in International tax structures In July 2015 a package of amendments were submitted into Cyprus Parliament and have been voted into law. A second pack is expected
More informationArgentine tax reform: A review of key provisions
10 January 2018 Global Tax Alert News from Americas Tax Center Argentine tax reform: A review of key provisions EY Global Tax Alert Library The EY Americas Tax Center brings together the experience and
More informationTax risks for the industry: Nearest perspectives. Andrei Ignatov Partner
Tax risks for the industry: Nearest perspectives Andrei Ignatov Partner State tax policy on international taxation Politicalcontext Statements by government officials and the head of state (e.g., Budgetary
More informationWithholding tax on cash and in-kind benefits in Slovakia. April 2015
Withholding tax on cash and in-kind benefits in Slovakia April 2015 Introduction As of 1 January 2015, benefits provided to healthcare providers, their employees or medical staff ( HCP / HCO ) by a pharmaceutical
More informationNon-resident chargeable gains on UK property collective investment vehicles
January 2019 Draft Finance Bill clauses Non-resident chargeable gains on UK property collective investment vehicles Summary of draft rules for collective investment vehicles (CIVs) In addition to the new
More informationAustria: Notification obligation regarding Country-by- Country Reports (CbCR) by 31 December 2017
No. 12/2017 21 November 2017 International Tax Review Current information on international tax developments provided by EY Austria Austria: Notification obligation regarding Country-by- Country Reports
More informationAccounting treatment of taxes
Accounting treatment of taxes Issues paper presented at the EPSAS WG Meeting Rome, 22-23 November 2016 The better the question. The better the answer. The better the world works. Contents Introduction
More informationGibraltar tax facts. 1 July 2017 to 30 June 2018
Gibraltar tax facts 1 July 2017 to 30 June 2018 Personal tax Choice of personal tax systems Taxpayers may opt to be taxed under the Gross Income Based System (see (A) below) or the Allowance Based System
More informationJulian Bohorquez/Zurich/CH/Amicorp,
www.amicorp.com May 14 Wealth Structuring For High Net Worth Individuals From Global Growing Markets Wealth Structuring Issues, Trends and Solutions - Russia Julian Bohorquez/Zurich/CH/Amicorp, Presented
More informationAustralia s revised exposure draft on hybrid mismatch tax rules: A detailed review
19 March 2018 Global Tax Alert Australia s revised exposure draft on hybrid mismatch tax rules: A detailed review EY Global Tax Alert Library Access both online and pdf versions of all EY Global Tax Alerts.
More informationInternational Tax Russia Highlights 2018
International Tax Russia Highlights 2018 Investment basics: Currency Russian Ruble (RUB) Foreign exchange control Some exchange control restrictions apply to Russian residents (including Russian citizens
More informationROMANIA GLOBAL GUIDE TO M&A TAX: 2018 EDITION
ROMANIA 1 ROMANIA INTERNATIONAL DEVELOPMENTS 1. WHAT ARE RECENT TAX DEVELOPMENTS IN YOUR COUNTRY WHICH ARE RELEVANT FOR M&A DEALS AND PRIVATE EQUITY? The new Romanian Fiscal Code, in force starting 1 January
More informationAustralia s proposed Diverted Profits Tax to affect many multinational businesses
2 December 2016 Global Tax Alert Australia s proposed Diverted Profits Tax to affect many multinational businesses EY Global Tax Alert Library Access both online and pdf versions of all EY Global Tax Alerts.
More informationDoing business in the Russian Federation
Doing business in the Russian Federation Introduction 3 Doing business in the Russian Federation Introduction This guide has been prepared by EY Russia in order to provide a quick overview of the legal
More informationMandatory transfer pricing documentation and penalty regime to be introduced in Singapore
Issue 12 17 July 2017 Transfer pricing alert Mandatory transfer pricing documentation and penalty regime to be introduced in Singapore Overview On 19 June 2017, the Ministry of Finance (MOF) released the
More informationSWEDEN GLOBAL GUIDE TO M&A TAX: 2017 EDITION
SWEDEN 1 SWEDEN INTERNATIONAL DEVELOPMENTS 1. WHAT ARE RECENT TAX DEVELOPMENTS IN YOUR COUNTRY WHICH ARE RELEVANT FOR M&A DEALS AND PRIVATE EQUITY? Effective as of 1 January 2016, dividend income is not
More informationEU AG issues opinion on Danish withholding tax on dividends and interest
2 March 2018 Global Tax Alert EU AG issues opinion on Danish withholding tax on dividends and interest EY Global Tax Alert Library Access both online and pdf versions of all EY Global Tax Alerts. Copy
More informationDoing Business in Russia
Doing Business in Russia Vladimir Abramov Partner Ernst & Young (CIS) B.V. The current economic situation shows that Chinese companies will be actively expanding their presence on the world market in the
More informationUS Tax Reform Update. 30 January 2018
US Tax Reform Update Introduction Aaron Topol Partner and Leader EY Asia-Pacific Tax Desk (US) Hong Kong Ernst & Young Tax Services Limited Robert King Partner and Leader Business Tax Advisory Vietnam
More informationGlobal Tax Alert. Spain releases draft bill of Spanish tax system reform. Executive summary. Detailed discussion
25 June 2014 Spain releases draft bill of Spanish tax system reform EY Library Access both online and pdf versions of all EY Global Tax Alerts. Copy into your web browser: http://www.ey.com/gl/en/ Services/Tax/International-
More informationReal estate funds. Are you leaving money on the table?
Real estate funds Are you leaving money on the table? Relevant to real estate fund managers or those managing investments under a segregated account mandate In a rapidly changing tax environment, it is
More informationSTEP ISRAEL 20TH ANNUAL CONFERENCE DAN TEL AVIV HOTEL JUNE 19-20, 2018
STEP ISRAEL 20TH ANNUAL CONFERENCE DAN TEL AVIV HOTEL JUNE 19-20, 2018 CANADIAN TAX UPDATE June 10, 2018 Stephen S. Ruby Partner MULTILATERAL CONVENTION On May 28, 2018, Canada tabled a Notice of Ways
More information