The Russian Ministry of Finance recently published Letter No. 03-08-05/57368, which provides guidance on corporate tax exemptions provided for profits of certain controlled foreign corporations (CFC). According to the letter, the profits of a CFC will be exempt from tax in Russia if it meets at least one of the following conditions:
- The CFC is a noncommercial entity that does not distribute its profits among its shareholders or other persons;
- The CFC was created in a Eurasian Economic Union …