On 22 October 2014, the latest, and likely final, draft of Russia's new controlled foreign company rules were submitted to the State Duma. Hearings for the draft rules will take place in November, and if approved, the new rules will apply from 1 January 2015. Key aspects of the current draft include:

Conditions for CFC Profit Exemption

The profits of CFCs will be exempt from Russian tax whe…