Tax law and tax disputes

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.

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).

On changes in tax monitoring Adopted and planned changes in the regulation of tax monitoring.

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)?

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.