Tax law and tax disputes

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.

Numerous amendments to the Tax Code

Pepeliaev Group advises of the contents of amendments to the Russian Tax Code made in connection with the implementation of the main avenues of tax policy for 2024-2026.

A set of amendments have been adopted regarding the tax on excess profit

Pepeliaev Group comments on the law on the tax on excess profit and the associated amendments to the Tax Code.

On the Administrative Penalties for Violations Related to Corporate Tax PGP Tax Consultancy advises that the Prime Minister of the UAE Mohammed bin Rashid Al Maktoum has issued Cabinet Decision No. 75 of 2023 on the Administrative Penalties for Violations Related to the Application of Federal Decree-Law No. (47) of 2022 on the Taxation of Corporations and Businesses. This Decision came into effect on 1 August 2023.

Digital Public Consultation related to UAE Corporate Tax in Free Zones The Ministry of Finance is launching a Digital Public Consultation for Free Zone Companies. Responses should be submitted through the form by no later than 2 August 2023.

The Constitutional Court has restricted the Russian Federal Tax Service’s right to audit controlled transactions By Resolution No. 41-P dated 14 July 2023 which was adopted further to an appeal of VimpelCom PJSC, the Russian Constitutional Court held that provisions of the Russian Tax Code are inconsistent with the Constitution which relate to the calculation of the period for a controlled transaction to be audited where an updated notification has been submitted but where information regarding the transaction has already been included in the original notification.

Free Zone companies under Corporate Tax

The long-awaited Cabinet and Ministerial Decisions on how Free Zone Residents will be subject to Corporate Tax were recently published.

Cabinet Decision No 55 of 2023 determines Qualifying Income for the Qualifying Free Zone Person for the purposes of Federal Decree-Law No. 47 of 2022 on the Taxation of Corporations and Businesses. Ministerial Decision No. 139 of 2023 disclosures Qualifying Activities and Excluded Activities.

We prepared a newsletter on how Free Zone Residents will be subject to Corporate Tax.

The intended amendments to the special administrative region (SAR) regimes. clarifications with regard to the types of investment by an international holding company (IHC) for the purpose of applying tax benefits

A draft law has been put before the State Duma to clarify the forms and types of investment for international holding companies when they apply tax benefits in special administrative regions.

The procedure is being changed for gaining access to a company’s information systems in the event of tax monitoring On 13 March 2023 the Russian Federal Tax Service signed Order No. ED-7-23/163@, which regulates the procedure for information systems of companies applying tax monitoring to integrate with the Nalog-3 Automated Information System.

Numerous amendments to tax legislation have been adopted Numerous amendments to tax legislation have been adopted, including those related to the special military operation.

Measures of support have been adopted for mobilised individuals and companies that they own The Russian Government has extended deadlines for making mandatory payments and for submitting tax reports and has established other measures of support for mobilised individuals and companies that they own.

New tax benefits for IT companies: the state continues to stimulate the domestic information technology industry On 14 July 2022, a law  came into force that introduced new measures to stimulate the domestic information technology industry. In particular, the conditions for obtaining tax benefits have been simplified, and the corporate profit tax rate has been reduced to zero for 2022-2024.