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Russia
2.4 Tax policy outlook for 2015 — detail
Corporate income taxes
•
2015 and statutory CIT rates will remain the same.
The De-offshorization legislation
• The new Law (which came into force on 1 January 2015) will
govern the determination of a controlled foreign company
(CF) and when Russian residents are to be recognized as
controlling persons. The criterion of recognition of a Russian
resident whose participation in a CFC exceeds 50% as a
controlling person will be applicable only during 2015.
• The Law provides the criteria for determining when a
company’s place of effective management will be considered
from a foreign recipient that the organization has an actual
right to receive the income in question. In addition, the Law
allows the actual owner of income to apply the provisions
of a treaty or domestic law to income paid from a Russian
source to a foreign person resident in a treaty jurisdiction
which is not the actual owner, provided that in the event of
the actual owner being resident in Russia, the tax authority
in the place of registration of the company which is the
and other types of income. The Law also states that if tax
on income of a foreign company is withheld as a result of
tax control measures, the actual owner of income may
subsequently apply for a refund of excess tax withheld.
Russian draft law on extension of the thin capitalization
rules submitted to State Duma
•
“Concerning the Introduction of Amendments to Article
269 of Part Two of the Tax Code of the Russian Federation
January but consideration of the bill has been postponed
until another plenary session.
• At this time this document was published, no revised text has
been published. Representatives of the Ministry of Finance
have suggested that amendments will be made to the
formula for the thin capitalization ratio for foreign currency
debts to exclude the impact of any devaluation of devaluation
of the ruble after 1 July 2014 (which could otherwise be
short-term measure and effective until the end of 2015. The
required changes are expected to be introduced in time for
the second reading.
•
the thin capitalization rules by replacing the current criteria
relating to Russian organizations with foreign shareholders
with new criteria relevant to Russian organizations (and
foreign companies treated as Russian organizations for
The draft also provides for the exclusion of loans from
third-party banks from the scope of thin capitalization rules,
provided that certain conditions are met.
Personal income tax
• In 2014 the tax rate on dividends and participation income
received was 9%, in 2015 – 13%.
VAT, GST and sales taxes
•
in 2015.
A number of amendments will come into force in 2015
• The Federal Law which introduces a new tax administration
regime for large taxpayers with respect to the exchange of
information (Tax Monitoring) between tax authorities and
taxpayers will come into force on 1 January 2015.
• The Federal Law introducing tax maneuver for oil and gas
sector will come into force on 1 January 2015. Excise duty
will increase, at the same time custom duty will decrease.
• From tax periods 2015 VAT declaration includes information
from the VAT invoices, received and issued.
• A federal law providing that the tax base in respect of
individual property is determined by their cadastral value will
come into force from 1 January 2015.
• Untaxable amount for calculation of insurance contributions
in Medical insurance fund will be repealed.
2.5 Fiscal stimulus in 2015
The outlook for global tax policy in 2015 | 155