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Tax law and tax disputes


The Tax Code has been supplemented with chapter 3.6, which establishes taxation specifics of implementing an APECI Pepeliaev Group advises that on 28 June 2022, two federal laws were adopted that amend the Tax Code and Federal Law “On protecting and encouraging capital investments in the Russian Federation” and that are aimed at improving the mechanism of APECIs.
The Government put before the State Duma a draft law on the taxation of digital rights On 14 April 2022 the Government put before the State Duma a draft law on the taxation of digital rights (transactions with digital financial assets).
The Russian Federal Tax Service has confirmed that it is legal to separate IT units into individual legal entities in order to receive tax benefits Pepeliaev Group advises that, according to the position of the Russian Federal Tax Service, the reorganisation of a legal entity as a result of which a standalone IT company is created cannot be considered by tax authorities to be a distortion of facts of economic life and qualify as the application of a tax evasion scheme.
The deadline has been extended for profit tax to be paid in advance in March Pepeliaev Group advises that the Russian Government has extended by a month, until 28 April, the deadline for profit tax to be paid in advance. It was due to expire on 28 March.
Amendments to the special administrative region (SAR) regime. Part I: new benefits and new requirements The regulation of the activities of the SAR residents have been amended. A new law has been published that extends the list of tax benefits for international holding companies (“IHCs”) (Federal Law No. 66-FZ dated 26 March 2022). In addition, on 25 March 2022, Federal Law No. 18-FZ dated 25 February 2022 comes into force, which introduces additional requirements to apply tax benefits and provides for the possibility of obtaining the status of an ICH for Russian companies as well. We have considered the amendments proposed by these laws in aggregate and as completely interdependent.
The law has been passed on measures of tax support for business Pepeliaev Group advises that, on 22 March 2022, the State Duma (the lower house of Russia’s parliament) passed the law containing a package of tax measures to support business.
A special procedure is being revisited for initiating criminal cases for tax offences Pepeliaev Group advises that, on 9 March 2022, a Federal Law came into effect to re-introduce a special procedure for initiating the criminal cases for which articles 198 to 199.2 of the Russian Criminal Code provide.
Fourth stage of the ‘capital amnesty’: the conditions are the same, but new items to declare have arisen

Pepeliaev Group advises that on 14 March 2022 the law on the fourth stage of the ‘capital amnesty’ came into force. This law was adopted at the initiative of the Russian Government. Still, the ‘amnesty’ has a procedural form for the voluntary declaration by individuals of assets (filing a special declaration).

The Tax Code will be amended drastically to reflect the measures aimed at supporting business during sanctions

Pepeliaev Group advises that on 11 March 2022 the State Duma adopted in the first reading a draft law containing a package of tax measures to support business.

Numerous amendments to the Russian Tax Code Federal laws have been adopted which are aimed at implementing the Main Lines of tax policy and which extensively amend the Russian Tax Code.
The repatriation of foreign trade revenue has been partially abolished Starting from 1 July 2021, the statutory obligation to repatriate has been abolished for the major part of foreign trade contracts whereby residents generate revenue (‘export’ contracts).