Russia Clarifies CFC Exemption Not Affected by Tax Treaty Suspension Unless There is a Lack of Information Exchange

The Russian Ministry of Finance recently published Guidance Letter No. 03-12-11/2/11449 of 12 February 2024 concerning the tax exemption for controlled foreign company (CFC) profits when a CFC is in a jurisdiction with which Russia has a tax treaty. This exemption generally applies unless a jurisdiction does not provide for the exchange of information with Russia. In this regard, the Ministry was asked how the exemption applies in cases where the tax treaty with a particular jurisdiction has …