Analytics and brochures

On 27 June 2018, the Russian President signed Federal Law No. 163-FZ On amending the Federal Law ‘On registering foreign nationals and stateless persons with migration authorities in Russia’.

Pepeliaev Group advises that the Russian Federal Tax Service (the ‘Federal Tax Service’) has disseminated among tax authorities written explanations regarding the issues of using the concept of ‘a person that enjoys the beneficial ownership of income’ (a beneficial owner of income) when international double taxation treaties are applied.

Law firm Pepeliaev Group advises that the OECD is carrying out a public consultation on the scope of the future revision of Chapter VII (Intra-Group Services) of the Transfer Pricing Guidelines. The issues proposed for consideration attest to the changes in the approaches OECD countries are taking to substantiating expenses on intra-group services and to whether it is possible to bring such approaches considerably closer to the practices of Russian tax authorities.

Pepeliaev Group advises of an improvement of the position of taxpayers in court disputes relating to the application of beneficial rates under DTTs in the context of intra-group loans. 

Pepeliaev Group advises that, on 1 June 2018, the law “On financial transactions” will come into effect which amends certain regulations concerning loan agreements.

Pepeliaev Group reminds you that the timeframe for the registration of foreign nationals with migration authorities during the above period has been reduced considerably.