Overview of tax events for October 2023

Regulatory developments

A law has been passed which improves the procedure for taxing residents of special economic zones, priority development areas, and of the Free Port of Vladivostok (instruments of tax legislation can have retroactive effect if they explicitly provide for this; the mandatory conditions for conducting tax monitoring have been removed).

The Russian Ministry of Finance is starting negotiations with ‘friendly’ countries regarding the renewal of the current or the signing of a new double tax treaty based on the standard proposal, with the rates for the payment of dividends, interest and royalties being at 10%.

Case law

The Russian Ministry of Finance:

• State Secretary and Deputy Minister of Finance Alexey Sazanov has explained under which circumstances the tax parameters may remain unchanged, and under which the authorities may ask companies to share their excess profit;

• he has also elaborated on the priorities when countering bad-faith taxpayers;

Interview: State Secretary and Deputy Minister of Finance Alexey Sazanov on the search for the fairness and historical feasibility of Personal Income Tax.

The authorities intend to enhance control over transactions with related parties.

The Russian Federal Tax Service:

• has changed the rules for publishing open-source information concerning organisations (Order No. ED-7-14/578@ dated 28 August 2023);

• has clarified the procedure for for paying tax on property according to its cadastral value (Letter No. BS-4-21/11940@ dated 19 September 2023);

• has clarified issues of administrative liability being imposed for currency offences (Letter No. D-5-17/39@ dated 14 July 2023).

The EU has left Russia in the blacklist of countries which do not cooperate in tax matters.

Translated by the Translation Department of Pepeliaev Group