On 26 June 2014, additional amendments to Russia's proposed CFC rules introduced earlier this year were published. This is the third draft of the rules.
The main changes include:
- The threshold for determining if a taxpayer is a controlling person is increased from 10% to 50% direct or indirect participation, solely or together with related parties
- Additional situations where a foreign organization will be excluded from being characterized as a CFC include:
- Companies taking part in governmen…