Fisc russe

Tax Flash Report by PwC experts CFC rules: over 100 jurisdictions land on N ovember 2015 / Issue No. 35 FTS³blacklist´ In brief The Russian Federal Tax Service (FTS) has released for public discussion a so-called³blacklist´of those countries and jurisdictions that the FTS deems not to have provided proper exchange of tax information with the Russian 1 tax authorities . Certain provisions of Russia's controlled foreign company (CFC) legislation make reference to such a list (e.g. tax exemptions for CFC profits in Russia). The business community had been expecting that the FTS list would more or less match the list developed by the 2 MinFin , which encompasses 40 countries (the zero profits tax rate cannot be applied to dividends received from the listed countries). However, the FTS list has turned out to be three times longer than the MinFin's list and encompasses even such jurisdictions as United Kingdom, Switzerland, Austria and Brazil (see Appendix 1). The document is now at the public discussion stage. We hope that the FTS will accommodate the needs of the business community by reducing this list at least for the initial years of applying the CFC rules (the list may be reviewed on an annual basis). In detail Please note that Article 25.13-1 of the Russian Tax Code (RTC) describes situations when CFC profit is tax exempt in Russia. In total, there are eight such situations.