- 29 November 2023PAS MessengerAmendments relating to personal income tax payment were made to the Russian Tax Code by Federal Law No. 539-FZ of 27 November 2023.
- 28 November 2023Law MessengerIn dealing with tax disputes, the courts often proceed from the premise that a violation of certain procedures of tax law does not entail the unconditional reversal of the tax authorities’ decisions following a tax audit. Nevertheless, the tax authorities’ departure from procedural law may become one of the main reasons for reversing a decision to impose tax liability.
- 28 November 2023Tax MessengerThe second half of 2023 has yielded an abundance of possible amendments to the Tax Code of the Russian Federation aimed at enhancing tax control in relation to related party transactions. The B1 team has prepared an overview of expected changes to the transfer pricing rules.
- Tax MessengerThe heirs of a deceased individual entrepreneur filed suit to claim a refund of tax overpaid by the deceased. The lower courts denied the suit on grounds that the individual entrepreneur did not claim the refund during his lifetime.
- 16 November 2023Tax MessengerOn 13 November 2023, the draft order of the Federal Tax Service of Russia was published on the Federal Portal of Draft Regulations to establish the list of countries (territories) that fail to ensure the automatic exchange of country-by-country (CbC) reports on a regular basis.
- 16 November 2023PAS MessengerDecree No. 1883 of the Government of the Russian Federation dated 10 November 2023 establishes a base cap for the assessment of insurance contributions starting 1 January 2024. The amount will be RUB 2,225,000.
- 14 November 2023Tax MessengerMandatory product marking was introduced in 2016. Key milestones of the system operation over the seven years include the following: more than 600,000 marking system participants, 16 goods categories covered and so on.
- Tax MessengerThe end of 2023 has produced a rich crop of changes to Russian tax law. On 8 November 2023 came the publication of the second draft of a bill which makes substantial changes to the tax rules governing income received by foreign organisations from sources in the Russian Federation. The key potential changes to the Russian Tax Code are highlighted in the article.
- 31 October 2023Tax MessengerOn October 23, 2023 the UAE tax authorities published a Transfer Pricing Guide on its official site, including explanations and recommendations for analyzing whether financial transaction prices are in line with the arm’s-length principle. This alert reviews the published recommendations on intragroup financial transitions, which must be taken into consideration when making decisions on pricing and carrying out intragroup financial transactions with companies in the UAE.
- 10 October 2023PAS MessengerEdict No. 734 of the President of the Russian Federation of 29 September 2023 (the “Edict”) and Regulation No. 2723-r of the Government of the Russian Federation of 6 October 2023 (the “Regulation”) make changes in the procedure for entering and exiting the Russian Federation for Ukrainian citizens.
- 9 October 2023Tax MessengerTemporary periodic declaration is a special type of declaration that is used when the exact quantity and/or customs value of exported goods is not known at the time of declaration.
- 29 September 2023Tax MessengerThe new Tax Code of the Republic of Tajikistan (hereinafter, the TCRT), which includes transfer pricing provisions (hereinafter, the TP Rules), entered into legal force on 1 January 2022.
- 28 September 2023Tax MessengerOn 20 September 2023, the Supreme Court’s Chamber for Commercial Disputes confirmed the legality of a customs authority’s refusal to release goods due to the declarant’s failure to present the goods for customs inspection.
- 28 September 2023PAS MessengerThe Russian government has prepared a draft Decree “On the Single Base Cap for the Assessment of Insurance Contributions, Starting 1 January 2024” and presented it for public discussion.
- 1 September 2023Law MessengerAt a meeting of the Government Commission held on 9 August, a new approach of the Ministry of Finance and the Bank of Russia to the issuance of permits for dividend payments (profit distributions) by residents to “unfriendly” shareholders (participants) was announced.
- Tax MessengerImporters of medical goods often fail to claim an exemption from import VAT when declaring goods – for example, in situations where, at the customs clearance stage, they lack documents confirming their eligibility for the benefit. In these cases, importers pay import VAT at the standard rate of 20%.
- 22 August 2023Tax MessengerSubparagraph 3 of paragraph 2 of Article 61.11 of the Law on Bankruptcy establishes the presumption of driving debtor into bankruptcy by controlling parties — in particular, if total outstanding additional tax charges exceed 50% of third-priority creditors' total claims in respect of the principal debt.
- 14 August 2023Law MessengerOn 4 August, the President signed Law No. 422-FZ that introduces new special economic measures, extends the list of parties to whom such measures may be applied, and determines the range of parties responsible for implementing the measures. The amendments will enter into force on 1 February 2024.
- 9 August 2023Tax MessengerOn 4 August 2023, the Arbitration Court of Belgorod Region decided in Case No. A08-12115/2021 that it was lawful for dividends paid by an importer to its founder that simultaneously acted as the seller of goods to be included in the customs value of goods.
- Tax MessengerOn 8 August 2023 the President of Russia signed Edict No. 585 suspending the effect of certain articles of double taxation treaties with "unfriendly" countries.
- 9 August 2023Tax MessengerOn 14 July 2023, the Constitutional Court of the Russian Federation published Ruling No. 41-P in a case challenging the constitutionality of the first paragraph of clause 2 of Article 105.17 of the Tax Code of the Russian Federation in connection with a claim filed by Vimpel-Communications PJSC.
- Tax MessengerOn July 28, 2023 the Supreme Court of the Russian Federation issued a ruling on Case No. А55-3526/2022, concerning the legitimacy of late payment interest assessed for failure to make customs payments on time.
- Tax MessengerThe law establishes that, if a vehicle previously imported to Russia is exported to other countries of Eurasian Economic Union, the recycling fee paid on it may be refunded if four conditions are met.
- 1 August 2023Tax MessengerThe law No. 389, signed by the Russian President and published on July 31, 2023, establishes a special tax regulation of personal funds, making them more attractive in terms of taxation.
- Tax MessengerOn July 7, 2023, the Arbitration Court of Moscow Region handed down a decision on Case No. А41−49 426/2022, which involved a customs authority’s refusal to grant an exemption from customs payments on grounds that temporarily imported spare parts installed on an airplane in the Russian Federation had left the Eurasian economic union with the airplane.
- 26 July 2023Tax MessengerOn 21 July 2023, the State Duma passed in the third reading the draft Federal Law "On Windfall Tax" and the draft Federal Law "On Amendments to Part One and Article 270 of Part Two of the Tax Code of the Russian Federation". In this alert, we address key specifics of windfall tax introduced by the Draft Laws.
- PAS MessengerA draft law that would make numerous amendments to the Russian Tax Code was adopted by the State Duma in its third reading on 21 July. One key change affects personal income tax on the compensation of individuals working abroad.
- Law MessengerOn 20 July 2023, the State Duma of the Russian Federation adopted in the second and third readings the Law "On the Regulation of Corporate Relations in Companies That Are Economically Significant Organizations" (Draft No. 176651-8). The law has been submitted for approval to the Federation Council.
- Tax MessengerThe Istanbul Financial Center (IFC) was opened by President Erdoğan on April 17. According to the official statement, the IFC, which has been built from scratch, contains the world's largest and most advanced infrastructure facilities.
- 20 July 2023Tax MessengerThis bulletin provides insights on the latest tax updates in Türkiye as well as the details of those legislative changes.
- Tax MessengerThe tax authorities have been increasingly focusing on improving the collection of additional taxes and levies resulting from conducted tax audits. Various tools and approaches are practiced throughout the tax administration process to collect the information.
- PAS MessengerOn 10 July 2023 Federal Law No. 316-FZ “On Amendments to the Federal Law ‘On the Legal Status of Foreign Nationals in the Russian Federation’” was signed and published. The Law makes changes in the procedure for hiring highly qualified specialists.
- PAS MessengerIn Ruling No. 35-P issued on 27 June 2023 the Constitutional Court of the Russian Federation once again expressed a position regarding basic principle of payment for overtime work. The Court qualified p.1 of Article 153 of the Labor Code as non-corresponding to provisions of the Constitution.
- PAS MessengerIn Ruling No. 32-P of 15 June, the Constitutional Court of the Russian Federation determined p.2 of Article 135 of the Labor Code as non-corresponding to provisions of the Constitution.
- Tax MessengerOn 1 June 2023 the United Arab Emirates introduced corporate tax, ushering in a new era in the country’s tax system. It is a trend we’re seeing throughout the MENA region.
- PAS MessengerA draft law that would make numerous amendments to the Russian Tax Code has been submitted to the State Duma following revision. One key change affects personal income tax on the compensation of individuals working abroad.
- Tax MessengerPresented in this alert is a brief overview of the additions made to the transfer pricing rules in the UAE based on the documents mentioned above.
- Law MessengerOn 19 May 2023, the US, the UK, Australia and Canada imposed new restrictive measures on Russia. The countries in question extended their sanctions lists mainly to include persons and entities connected with the defence and energy sectors.
- Tax MessengerIn April 2023, in a new round of hearings on case No. A09/1751/2021 (Bershka CIS LLC), the trial court rejected the importer’s claims for the invalidation of the customs office’s decisions requiring the inclusion of royalties and dividends in customs value.
- Law MessengerOn 16 May 2023, the State Duma passed in the first reading a bill (No. 337661-8) that allows international companies to be established through incorporation in the territory of special administrative districts and provides additional options for ICs in terms of the formation of management bodies and the structuring of equity capital.
- 18 May 2023Tax MessengerThe start date for corporate tax in the United Arab Emirates (1 June 2023) is fast approaching. Federal Decree-Law No. 47 of 2022 on the taxation of corporations and business was signed on 3 October 2022, but many questions remain over how the law will apply in practice to various kinds of companies.
- Tax MessengerA draft order "On Approval of the Procedure for Sending a Request to Submit Documents (Information) and for Submitting Documents (Information) at the Request of a Tax Authority via Information Systems of an Organisation to Which the Tax Authority has been Granted Access" has been published.
- Tax MessengerThis alert presents key findings from a survey of transfer pricing rules for financial transactions in countries classed as friendly to Russia, which multinational enterprises should take into consideration when making decisions about the pricing and conclusion of intra-group financial transactions in order to ensure compliance with local transfer pricing regulations.
- Law Messenger
On considering case No. A33−21 320/2021, the Economic Disputes Panel of the Supreme Court of the Russian Federation ruled that stating the wrong classification code for a part of goods when the total quantity of goods is correctly stated does not constitute a failure to declare goods.
- 24 April 2023Law Messenger
On 12 April 2023 the Office of Foreign Assets Control (OFAC) extended the list of persons covered by the US’s blocking sanctions. The UK and the EU have likewise extended their sanctions lists. The key changes are listed below.
- Tax Messenger
On 14 February 2023, the European Union Finance Ministers adopted a revised list of non-cooperative jurisdictions for tax purposes, adding four jurisdictions to the so-called "tax haven black" list (Annex 1): Russia, British Virgin Islands, Marshall Islands and Costa Rica and now the list includes 16 countries in total.
- 10 April 2023Tax MessengerThis alert contains a summary of the TP rules insofar as they apply to financial transactions and financial sector companies.
- Tax MessengerOver the last few decades many Russian companies have raised debt financing from foreign capital markets. This has been done by setting up special-purpose companies in accordance with the laws of foreign states.
- Tax MessengerOn 1 January 2022 the new Tax Code of the Republic of Tajikistan entered into force, which includes transfer pricing (TP) requirements. Presented below is an overview of the key provisions of the TP rules, which are broadly in line with the main international principles laid down in the OECD Guidelines.
- Tax MessengerSection VI "Tax Control in Relation to Transfer Pricing" of the Tax Code of the Republic of Uzbekistan came into force on 1 January 2022.
- Tax MessengerThe Federal Tax Service has been consistently extending the scope of the CRS rules, including requirements relating to the electronic reporting format. By 31 May 2023 financial market organizations must provide processed data for the 2022 reporting period in accordance with the new reporting format.
- Tax MessengerThe cassation court in the second round of adjudication on case No. A70−785/2021 upheld an importer’s claims that customs authority had acted wrongly in ordering royalties paid for know-how for the manufacture of finished product to be included in the customs value of imported equipment used in building a process line for the manufacture of that product.
- Tax MessengerThe Federal Tax Service has approved Order No. YeD-7−23/163@ of 13 March 2023 "On Approval of the Procedure for Access of Tax Authorities to an Organisation’s Information Systems".
- 14 March 2023PAS MessengerDecree No. 1 of Russia’s Chief Public Health Officer “On Clean-Up Vaccination against Measles in the Russian Federation,” dated 8 February 2023 (hereinafter, the Decree), will enter into legal force on 20 March 2023.
- 2 March 2023Law MessengerThe USA, the EU, the UK and other foreign states have introduced new restrictive measures against Russia (sanctions).
- 14 February 2023Tax MessengerRussia was included in the EU’s list of non-cooperative tax jurisdictions (the so-called ‘blacklist' - see Annex I).
- 13 February 2023Tax MessengerIn accordance with Law No. 7412 of 22 June 2022 on the Istanbul Financial Centre, companies registered in the Istanbul Financial Centre that sell goods purchased abroad in transit trade or intermediate in the purchase and sale of goods abroad have the right to reduce their corporate tax base by 50% (the standard corporate tax rate in Turkey in 2023 is 20%).
- Tax MessengerChanges to the rules governing the payment of VAT by tax agents came into effect from 1 January 2023.
- 7 February 2023Tax MessengerThe Federal Tax Service has published an updated List of Foreign States (Territories) with Whose Competent Authorities the Automatic Exchange of Country-by-Country Reports is Carried Out, approved by Order No. YeD-7−17/1226@ of 20 December 2022.
- 3 February 2023PAS MessengerLaw No. 2-FZ "On Mutual Ratification of the Agreement between the Government of the Russian Federation and the Government of the Republic of Belarus on Mutual Acknowledgment of Visas and Other Issues Related to the Entry of Foreign Citizens and Stateless Persons to Member Countries of the Agreement on Establishment of the Union State," dated 27 January 2023, entered into legal force on 1 February 2023.
- Law MessengerOn 29 December 2022, the President of Russia signed a number of laws aimed at striking a balance between attracting foreign investments into the Russian economy and averting possible risks associated with foreign investments in particular sectors.
- 19 January 2023Tax MessengerOn 9 November 2022, the Organisation for Economic Co-operation and Development (OECD) published its 2022 Report on the peer review of the automatic exchange of financial information in various jurisdictions.
- 13 January 2023PAS MessengerAmendments to Order No. 24 of the Ministry of Labour and Social Development of 26 January 2022 "Concerning the Conduct of Routine Monitoring for the Purposes of Supporting Employment" entered into force from 1 January 2023.
- 29 December 2022Tax MessengerThe operator of the digital product marking system is preparing to introduce new features to the digital marking system that will give businesses access to full and exhaustive information on any logged irregularities in the circulation of products.
- Law MessengerThe Governmental Commission for the Monitoring of Foreign Investments in the Russian Federation issued Minutes, in which it officially set out the conditions that affect decisions regarding the approval of transactions involving shares/interests held by persons from "unfriendly" countries and the payment of dividends to such persons.
- Tax MessengerThe Moscow Arbitration Court upheld claims brought by an importer in case for the invalidation of a customs authority’s decisions to include amounts of VAT on royalties in the customs value of imported goods.
- Law MessengerOn 28 November 2022, the EU Council unanimously adopted a decision to add violations of EU sanctions to the list of EU crimes.
- 24 November 2022Tax MessengerThe Volga District Arbitration Court upheld a customs authority’s claim for customs charges to be collected by levying execution on goods owned by the Russian final buyer (not the importer).
- Tax MessengerWe discuss the recent letter issued by the Ministry of Finance of Russia regarding a taxpayer’s request for the initiation of a mutual agreement procedure on transfer pricing between the governments of Russia and South Korea.
- 11 November 2022Law MessengerEdict No. 520 of 5 August 2022 imposed a ban on transactions involving shares and equity interests in strategic enterprises, certain fuel and energy companies and related service companies.
- 27 October 2022Law MessengerThere is now a whole range of presidential edicts and directives imposing various prohibitions and restrictions on transactions involving shares and equity interests in financial organisations.
- PAS MessengerDecree No. 22 of the Chief Sanitary Officer of the Russian Federation cancels the PCR testing requirement for Russian and foreign citizens.
- Tax MessengerOn 19 September 2022, the Ninth Arbitration Appeal Court upheld the trial court ruling on case No. A40−82 219/2022, in which the decisions of a customs authority were found to be lawful.
- 18 October 2022Law MessengerPresidential Edict No. 737, adopted on October 15, and the clarifications of Edict No. 618, issued on October 13 establish a new framework for transactions with companies linked to persons from "unfriendly" countries.
- Tax MessengerThe Federal Tax Service has published a "Review of Case Law on the Establishment of a Taxpayer’s Actual Tax Obligations" (Federal Tax Service Letter No. BV-4−7/13 450@ of 10 October 2022).
- 7 October 2022Tax MessengerThe Arbitration Court of the Krasnodar Region ruled as unlawful a customs authority’s decisions to require royalties for software products to be included in the customs value of imported goods.
- 28 September 2022PAS MessengerOn 27 September 2022 the State Duma adopted amendments to the Labour Code designed to regulate the status and rights o mobilised employees.
- 19 September 2022Tax MessengerOn 16 September, Swiss regulators announced that the exchange of tax information with Russia would be suspended.
- PAS MessengerOn 9 September 2022 the Council of the European Union adopted Decision on the suspension of the Visa Facilitation Agreement with Russia.
- Law MessengerEdict No. 618 eliminates the last major unregulated category of transactions involving parties from "unfriendly" countries: transactions with LLC interests.
- 6 September 2022Tax MessengerThe Federal Customs Service presents guidance on the application of import duty rates set by Government Decree No. 788 of 6 July 2018.
- 1 September 2022PAS MessengerEdict No. 585 of the President of the Russian Federation “Concerning Temporary Measures to Regulate the Legal Status of Citizens of the Donetsk People’s Republic, the Lugansk People’s Republic and Ukraine in the Russian Federation” was published on 27 August 2022.
- 31 August 2022PAS MessengerThe Russian Government published Decree No. 1352 concerning Grant Support for Talented Foreign Citizens and Stateless Persons Studying at Russian Organisations.
- PAS MessengerThe State Duma was presented with a draft law concerning an amendment to the Federal Law "Concerning Citizenship of the Russian Federation" to simplify the conferment of Russian citizenship on foreign citizens.
- 30 August 2022Tax MessengerArbitration Court adopted a ruling involving a dispute over whether royalties for the use of a trademark and VAT paid on those royalties by the importer as a tax agent should be included in the customs value of imported goods.
- 9 August 2022Tax MessengerThe Arbitration Court adopted a ruling on a dispute over whether royalties for the right to use trademarks in business activities and amounts of VAT on royalties paid by an importer as a tax agent should be included in the customs value of imported goods.
- 8 August 2022Law MessengerThe President of Russia signed an edict on special economic measures in the financial and fuel and energy sectors in connection with unfriendly actions of certain foreign states and international organisations.
- Tax MessengerAll Internet advertising directed at Russian users will have to be marked and subsequently recorded in a special system known as the Unified Register of Internet Advertising.
- 3 August 2022Tax MessengerThe Ninth Arbitration Appeal Court adopted a ruling on case, which concerned a dispute over whether amounts of royalties for the right to use trademarks, processes and know-how should be included in the customs value of imported goods.
- PAS MessengerThe payments will be subject to PIT at the rates of 13% (15%) for residents and 30% for non-residents.
- 25 July 2022PAS MessengerFederal Law No. 357-FZ concerning Amendments to the Federal Law "Concerning the Legal Status of Foreign Citizens in the Russian Federation" was published on 14 July.
- Law MessengerFederal Law No. 193-FZ extends the range of holders of exclusive rights in a trademark and establishes mandatory registration of a pledge of exclusive rights in a registered computer programme or database.
- 19 July 2022PAS MessengerDecree No. 1267 of the Russian Government "On the Annulment of Certain Acts and Certain Provisions of Acts of the Government of the Russian Federation" came into force.
- Tax MessengerFederal Law No. 324-FZ, passed on 14 July, establishes special provisions regarding the VAT, profits tax and personal income tax treatment of transactions involving digital financial assets.
- 18 July 2022Tax MessengerOn 5 July the State Duma passed in the first reading draft law setting out a range of amendments to the Federal Law "On Information, Information Technology and Information Protection".
- 15 July 2022PAS MessengerOn 11 July 2022 the President of the Russian Federation signed into force Edict No. 440 of 11 July 2022 and Edict No. of 29 April 2019.
- Tax MessengerThe FTS published Order, which approves the list of countries with whose tax authorities the FTS automatically exchanges country-by-country reports on an annual basis.
- Tax MessengerWe comment on the application of transfer pricing rules for intragroup financial transactions in the current economic environment.
- 8 July 2022Tax MessengerOn 5 July 2022 the State Duma passed in the third reading a bill proposing a number of amendments to Part Two of the Russian Tax Code.
- PAS MessengerThe Federal Law simplifies the rules for obtaining immigration documents for foreign citizens who are specialists in the field of information technology.
- Tax MessengerWe comment on the latest letters from the Federal Tax Service regarding transfer pricing regulations for cross-border transactions.
- 22 June 2022Law MessengerIn June the Russian authorities eased or eliminated most foreign exchange restrictions that had applied to residents since late February.
- 22 June 2022Law MessengerOn 22 June 2022, the Federation Council approved bill, which makes amendments to the Law of the Russian Federation "Concerning the Subsurface".
- PAS MessengerOn 16 June the Russian Government Regulation No.1552-r was published, which removes a number of restrictions on the entry of foreign citizens into Russia.
- 14 June 2022PAS MessengerThe draft Law on Amendments to Articles 8 and 13.2 of the Federal Law “Concerning the Legal Status of Foreign Citizens in Russia” has been passed in the first reading.
- Tax MessengerThe Arbitration Court adopted a ruling over the legality of decisions regarding the inclusion of software royalties in the customs value of imported goods.
- PAS MessengerRussia is to lift pandemic-related restrictions on foreigners entering the country by air and sea with effect from 14 June 2022.
- Law MessengerTemporary procedure for the fulfilment of monetary obligations by Russia, constituent entities, municipalities and residents has been introduced.
- PAS MessengerThe Government of the Russian Federation has issued Directive which removes restrictions to enter the Russia for some categories of foreign citizens.
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