Important changes to the migration registration process for foreign nationals in Russia 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’.

Explanations of the Russian Federal Tax Service regarding the application of the concept of a beneficial owner of income 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.

Anticipated changes to the OECD Transfer Pricing Guidelines regarding intra-group services

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.

New practice of applying a beneficial rate under a DTT to intra-group loans

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. 

Regulations for loan agreements have changed

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

Registration of foreign nationals with migration authorities during the 2018 FIFA World Cup

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

ESCROW: new opportunities

Pepeliaev Group advises that, starting from 1 June 2018, the Law on Financial Transactions[ has come into force, which considerably has expanded the opportunities of using the escrow mechanism.

The first regional law providing for an investment tax deduction for profit tax

Pepeliaev Group advises that, on 22 March 2018, the Legislative Assembly of the Republic of Karelia adopted a law introducing an investment deduction for profit tax.

Salaries in foreign currency to employees working abroad

Pepeliaev Group advises that on 18 March 2018 a Federal Law (“Law No. 44”) came into effect allowing more options to employers for making payroll payments in foreign currency.

If a company is entered into a sanctions list, it is no longer obliged to disclose information Pepeliaev Group advises of the exceptions that the Russian Government has introduced with respect to the rules governing companies disclosing information regarding their business activity.

The supreme court has clarified the application of a reduced tax rate under a double taxation treaty to dividends in conditions of thin capitalisation On 6 March 2018 the Judicial Board for Economic Disputes of the Russian Supreme Court issued its Ruling in the case of SUEK-Kuzbass JSC. In this Ruling the Judicial Board has clarified the rules for applying a reduced tax rate under the Double Taxation Treaty with Cyprus to interest under controlled debt which was reclassified as dividends when the lender is not a shareholder of the borrower.

New rules for companies wishing to join a syndicated credit (loan) agreement

Pepeliaev Group advises that new statutory corporate rules have taken effect for companies wishing to join a syndicated credit (loan) agreement.