Russia's new controlled foreign company (CFC) rules were signed into law by Russian President Vladimir Putin on 14 November 2014. Federal Law No. 376-FZ, introduces several amendments to the Russian Tax Code regarding the taxation of the profit of CFCs. The following summarizes the main rules introduced by the new law.
Controlling Person
Under the new rules, criteria for determining if a Russian resident is a controlling person of a CFC will be transitioned as follows:
- In 2015, a Russian…