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Tax law and tax disputes

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28December2023
The Supreme Court regarding tax on the extraction of gold concentrates

The Russian Supreme Court has solved the issue of a royalty coefficient when mineral extraction tax is assessed on concentrates which contain gold and other precious metals.The Court’s decision allows for excessive tax payments to be avoided and is relevant for all payers of mineral extraction tax.

01December2023
Amendments to the Tax Code: autumn 2023 A number of amendments to the Russian Tax Code, which have been introduced by a law adopted in autumn 2023. The majority of the amendments will apply starting from the new year of 2024, while some will come into effect later.
07November2023
Updated rules of the Corporate Tax regime for Free Zone Persons
The earlier published Cabinet Decision No. 55 of 2023 and Ministerial Decision No. 139 of 2023 concerning the Corporate Tax regime for Free Zone Persons have been repealed and replaced 
03November2023
Amendments have been made to the conditions of tax stabilisation for residents of special economic zones

On 2 November 2023, the Federal Law supplementing the Russian Tax Code and changing the content of the “stabilisation clause” for residents of special economic zones was signed by the Russian President and published.
The amendments will come into effect on 1 January 2024.

11October2023
How to “maintain adequate substance” in a free zone to enjoy a 0% Corporate Tax rate? The requirement to ensure adequate substance for taxation purposes appeared in article 18(1)(a) of the Corporate Tax Law. It stipulates that taxpayers in the UAE’s free zones which “maintain adequate substance” in the UAE may apply a 0% tax rate to qualifying income.
10October2023
The application form has been approved for excluding from the Unified State Register of Legal Entities (the “USRLE”) a legal entity classified as a small or medium entrepreneur

The Federal Tax Service has approved an application form (form р19001) for the “simplified liquidation” of some small or medium entrepreneurs.

25September2023
The cash method of accounting in UAE corporate taxation

Article (20)(5)(a) of the Corporate Tax Law  authorizes the MoF to ‘prescribe … the circumstances and conditions under which a Person may prepare financial statements using the cash basis of accounting’. On May 9, 2023 the MoF exercised this authority in Decision No. 114 allowing to ‘prepare Financial Statements using the Cash Basis of Accounting, in any of the following instances: 1. Where the Person derives Revenue that does not exceed AED 3,000,000. 2. In exceptional circumstances and pursuant to an application submitted by the Person to the Authority’. What else do we know about this cash method? 

13September2023
Tax reclassification of advertising and marketing services provided in favour of foreign companies The practice of conducting tax audits aimed at reclassifying advertising and marketing services provided to foreign companies has spread.
29August2023
Small Business Relief for Corporate Tax in the UAE The FTA has just released a Corporate Tax Guide on Small Business Relief for taxpayers with Revenue of less than or equal to AED 3,000,000 (approx. USD 800,000).
28August2023
On changes in tax monitoring Adopted and planned changes in the regulation of tax monitoring.
22August2023
Distribution from a designated zone in the UAE. Case study

A distribution company (‘Distribution Co’) is incorporated in a free zone in the UAE. This zone is not included in the list of the designated zones. However, Distribution Co buys products and orders services from third parties to transport and store them in a UAE designated zone, and then distributes to the UAE mainland or abroad arranging delivery to the buyers (customers). Does this activity qualify for 0% Corporate Income Tax (CIT)?

09August2023
Most of the articles of double tax treaties with ‘hostile’ states have been suspended

Pepeliaev Group advises of the implications of the Russian President’s Decree, suspending most of the articles of double tax treaties with ‘hostile’ states.