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Nikolay Harivulo

  • 18 August 2017

    On June 7 2017 Russia, alongside 68 other states and jurisdictions, signed the Multilateral Convention to Implement Tax Treaty-Related Measures to Prevent Base Erosion and Profit Shifting (BEPS), which was developed to implement Action 15 of the BEPS Plan.
    The convention contains provisions that are binding for each signatory. It also contains numerous optional provisions, the application of which with respect to a particular double tax treaty (DTT) is at the discretion of each party to the DTT.

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  • 23 June 2017

    On March 23 2017 the Federal Tax Service issued a notification entitled On Identifying the Circumstances of an Unjustified Tax Benefit (ED-5-9/547@), which summarises the law enforcement practice associated with assessing the validity of a tax benefit in disputes relating to bad-faith contracting parties.

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  • 25 April 2017

    Companies may borrow necessary monetary funds in particular, in the form of credits and loans, commodities and commercial credits. In this regard, under certain conditions, the company may have a controlled indebtedness, for which the accounting of expenses for profit taxation purposes should be made according to the special rules regarding so-called 'thin capitalisation' stipulated in Article 269 of the Tax Code.

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  • 10 March 2017

    The procedure for transferring previous years' losses to future tax periods for the purpose of calculating corporate income tax has changed substantially for 2017. Under Article 283 of the Tax Code, taxpayers that incurred losses in previous years can reduce the present year's tax base for all or part of the amount of the losses.

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  • 22 December 2016

    During 2015 and 2016 the dispute between taxpayers and the tax authorities regarding the exclusion of multinational enterprise (MNE) groups' Russian subsidiaries from the requirement to pay corporate income tax on so-called 'intra-group expenses' came under scrutiny.

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  • 12 October 2016

    Price is an important element of all contracts, and IP transactions are no exception. Due to the unique character of most transferable IP assets, it is vital to define the contractual price clearly as, in case of disagreement, it is difficult to apply civil mechanisms to determine it.

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  • 29 April 2015

    In 2014 Russia adopted new legislation as part of the government's relatively new plan to combat tax evasion through financial transfers out of Russia to low-tax jurisdictions (deoffshorisation). In line with this intent, the Russian tax authorities focused their attention on cross-border transactions, including those involving IP assets, because Russian companies often hide a substantial part of their profits from Russian taxation through royalty payments made to intellectual asset management centres outside Russia.

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