Analytics and brochures

Pepeliaev Group advises that a risk exists that the Federal Tax Service's Inter-regional Inspectorate No. 1 for major taxpayers may file claims with respect to expenses on intragroup services incurred by an entity.

At federal level, the industry agreement has been adopted which sets additional obligations and automatically extends to companies in Russia's agricultural industry. To refuse to join the agreement, a well-grounded written refusal should be filed with the Russian Ministry of Labour and Social Protection (the 'Ministry of Labour') by 14 July 2018. 

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.