ey-global-tax-policy-outlook-for-2015

Russia
2.9 Country position on OECD Base Erosion
and Prot Shifting (BEPS) Action Plan
• Russian tax policy’s routine developments are in line with
the provisions of BEPS, but the Russian authorities didn’t
take action directly related to the publication of the BEPS
part of Russian legislation.
•
were developed and issued.
•
with regard to matters similar to issues disclosed in the BEPS
Action Plan:
•
Assistance in Tax Matters. The Convention provides a basis
for several forms of mutual administrative assistance in tax
matters: information exchange on request, automatically
and spontaneously; simultaneous tax examinations; tax
examinations abroad; tax recovery, including interim
important measure in the “de-offshorization” process
in Russia.
•
The Law will come into force on 1 January 2015. It’s
aimed at creating a mechanism to prevent the use of
and tax collection as it pertains to taxation of foreign
organizations. The new Law will govern the determination
of a controlled foreign company and when Russian
residents are to be recognized as controlling persons.
The Law provides the criteria for determining when
a company’s place of effective management will be
2.10 Pending tax proposals
• By July 2015 the Russian federal government, with the
participation of Russian business community, should develop
the draft of Law on capital amnesty. It is expected that the
bill as a part of a comprehensive anti-offshore legislation
will release of tax and criminal liability those, who return
to Russia the income previously transferred to "foreign
jurisdictions without paying appropriate taxes."
2.11 Consultations opened/closed
• The state authorities also considered a possibility to establish
at the legislative level a principle of taxpayer’s good faith,
the conditions upon which tax authorities were entitle to
restrict taxpayer’s rights, in the case of undue reduction of
tax obligations by improper expenditure or unearned tax
deductions.
• The bill was aimed against aggressive tax optimization
mechanisms, i.e. situations when taxpayers use formally
valid legal actions with the primary objective of default
(partial performance) of tax obligation or receipt of
compensation (refund, offset).
• Upon the results of public discussion further consideration of
the bill was postponed without date.
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