Law on CFCs
In 2015, the Federal Law dated 24 November 2014 No. 376-FZ “On Amendments to Parts One and Two of the Tax Code of the Russian Federation (regarding taxation of profits of controlled foreign companies and profits of foreign organizations)”, the so-called “Law on CFCs”. The essence of the adopted amendments amount to, in particular, the taxation of retained earnings of foreign companies (structures without legal entity status), owned and managed by Russian taxpayers. In addition, the Law on CFCs brings together other special rules to combat tax evasion (specific anti-avoidance rules – SAAR), such as the concept of the beneficial owner of income, tax residency of legal entities, as well as to counter indirect sales of immovable property.