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Russia Clarifies Inclusion of CFC Profits for Consolidated Tax Base Purposes and Indirect Participations

|Approved Changes|Russia
Russia

The Russian Ministry of Finance recently issued two guidance letters clarifying the inclusion of CFC profits for Russian tax purposes.

The first letter (03-12-11/3/5790) clarifies the non-inclusion of CFC profits in a consolidated tax base. According to the letter, for determining the corporate tax base for a consolidated group, the tax base is the total income received by all group members l…

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