Analytics Legal analytics Tax practice

19
April
2022

SPIC 1.0. Investors are given back the proven mechanism and the right to extend contracts due to the sanctions

On 14 March 2022, a law came into force reviving the SPIC 1.0 mechanism for new investment projects, and allowing extending the terms of contracts already concluded due to foreign sanctions. The amendments were developed by the Government as part of a package of anti-crisis measures.

As part of the development of this law, the Government has also clarified the rules for concluding SPIC 1.0. The updated rules came into effect on 1 April 2022.

Alexander Sitnikov, Managing partner
Maxim Grigoryev, Partner, Head of Southern directorate, Head of special projects
Alexandra Vasyukhnova, Partner, Head of Technology and Investment group
Natalia Abtseshko, Head of International projects group
Artem Gasparyan, Senior associate of Southern directorate
4
August
2020

Russia to initiate termination of double tax treaty with Cyprus

In early April, Russia sent a letter offering to amend the text of the agreement on avoidance of double taxation (DTT) by increasing tax rates in terms of taxable dividends and interest payments to Cyprus. However, after almost four months of negotiations, the parties failed to reach a consensus.

According to the information published by the Russian Ministry of Finance, with due regard to close economic and historical ties between the two states, the Russian party formulated options for a compromise and offered to swiftly hold (the ongoing week) face-to-face negotiations in Cyprus but received a refusal. Consequently, Russia’s Ministry of Finance announced that it would initiate denunciation of the DTT.
Alexander Sitnikov, Managing partner
Yuriy Ivanov, Head of Tax practice
9
March
2017

The Russian Federation Supreme Court’s new stance on price controls and thin capitalization

On February 16th, 2017 the Russian Federation Supreme Court Presidium approved the review of practices when hearing cases involving the application of individual provisions in section V.1. and article 269 in the Russian Federation Tax Code (RF TC).
Yuriy Ivanov, Head of Tax practice
17
February
2016

Changes to anti-offshore legislation in early 2016

On the 15th of February 2016, Russian President Vladimir Putin signed Federal Law No. 32 “On Amendments to Parts One and Two of the Tax Code and the Federal Law – On Amendments to Parts One and Two of the Tax Code (regarding the taxation of profits of controlled foreign companies and income of foreign organizations). “ This law amends existing Russian anti-offshore legislation. We present here the most interesting amendments, which should be taken into account when working with affiliated foreign companies and non-corporate tax planning tools.
Yuriy Ivanov, Head of Tax practice
28
July
2015

Summer harvest of laws

In the final days of the spring session of & nbsp; the State Duma of the Russian Federation adopted a number of important laws,   issues relating to public   procurement and competition   regulation. This article provides an analysis of the key provisions of the said legislation. (This legal update is available only in Russian)
Alexander Sitnikov, Managing partner
20
April
2015

Challenging the recommendations of the Federal Antimonopoly Service of Russia – the novel amendments of the Constitutional Court

On 31 March 2015, the Constitutional Court of the Russian Federation proclaimed Decree No. 6-P “On the case reviewing the constitutionality of Paragraph 1 of Part 4 of Article 2 of the Federal Constitutional Law – On the RF Supreme Court, and paragraph of the third Subparagraph 1 of Paragraph 1 of Article 342 of the Tax Code of the Russian Federation concerning the complaint of the Gazprom Neft Open Joint Stock Company”.
Alexander Sitnikov, Managing partner
Evgeniy Rodin, Partner, Head of "Resources. Industry. Restructuring"
3
December
2014

The international exchange of tax information in 2014

International cooperation on the exchange of tax information is moving into an active phase of collection and transmission of information. It is not surprising that the prevention of tax evasion is a priority for OECD countries. (This legal update is available only in Russian)
Yuriy Ivanov, Head of Tax practice
5
November
2014

Making VAT deductions when purchasing by electricity grid companies to compensate for losses

On 31 October 2014, the official website of the Russian Federal Tax Service published a letter from the Ministry of Finance of Russia dated 29.09.2014 No. 03-07-15/48602 on the legality of the application of deductions of value added tax in connection with the acquisition (compensation) by network organizations for electric energy losses occurring in grid facilities during transportation. (This legal update is available only in Russian)
Yuriy Ivanov, Head of Tax practice
9
October
2014

New in property taxes

On 04 October 2014, signed was the Federal Law No. 284-FZ “On Amendments to Articles 12 and 85 in the first part and the second part of the Tax Code of the Russian Federation and the annulment of the law of the Russian Federation “On taxes on the property of individuals” (hereinafter – the Law) which made a number of amendments to Russian tax legislation. (This legal update is available only in Russian)
Yuriy Ivanov, Head of Tax practice
10
April
2014

Changes in tax legislation

Russian President Vladimir Putin signed a Federal Law amending the first and second parts of the Tax Code of the Russian Federation and Certain Legislative Acts of the Russian Federation. (This legal update is available only in Russian)
Yuriy Ivanov, Head of Tax practice
12
August
2020

Double Taxation Avoidance Agreement with Cyprus will be preserved

As it became known earlier, during the negotiations Cyprus agreed to the conditions of Russia to amend the agreement on the avoidance of double taxation in terms of increasing the withholding tax to 15% in respect of dividends and interest. All of us are now waiting for the new reality of the Cyprus offshore. The same goes for Malta and Luxembourg. According to information from Deputy Finance Minister Alexei Sazanov, these countries "in general" agreed to the conditions proposed by Russia to revise tax agreements.

Who will be next in line? Find the answer in a brief analysis by VEGAS LEX.
Alexander Sitnikov, Managing partner
Yuriy Ivanov, Head of Tax practice
Khati Abdurakhmanova, Associate of Tax practice
13
August
2019

SPIC 2.0: Mechanism for development of innovations and introduction of modern technologies

On 2 August 2019, the President of the Russian Federation signed a legislative package concerning significant reforms for the mechanism of special investment contracts. Amendments refer to legal regulation in industrial policy and affect tax and fiscal legislation.

In this review, VEGAS LEX experts have analyzed changes, goals and prospects of the updated SPIC mechanism.
Alexander Sitnikov, Managing partner
Maxim Grigoryev, Partner, Head of Southern directorate, Head of special projects
Alexandra Vasyukhnova, Partner, Head of Technology and Investment group
Natalia Abtseshko, Head of International projects group
Artem Gasparyan, Senior associate of Southern directorate
19
April
2016

The Supreme Court is against illegal tax control over price levels

On 11 April 2016, the Judicial Chamber on Economic Disputes of the Supreme Court issued a ruling on Case No. A63-11506/14, and with that, sided with the taxpayer in a dispute with the tax authorities. The Supreme Court of the Russian Federation stated that the territorial tax authorities, within cameral and field tax audits, are not allowed to control the market price levels in transactions between related parties.
Alexander Sitnikov, Managing partner
Yuriy Ivanov, Head of Tax practice
27
August
2015

The adoption of VAT deductions in respect of compensation for the loss of electricity. Decision of the Supreme Court dated 29.07.2015

On 29 July 2015, the Judicial Panel on Economic Disputes of the RF Supreme Court issued a ruling on Case No. A51-5267/2013 and supported the position of the taxpayer – Artemovskaya Power Grid LLC, in a dispute with the tax authority about the possibility of making VAT deductions from the electricity purchased to compensate for losses. (This legal update is available only in Russian)
Yuriy Ivanov, Head of Tax practice
8
June
2015

Amendments to the Russian CFC rules and the capital amnesty

On 8 June 2015, President Vladimir Putin signed into law the Federal Law No.150-FZ "On amendments being made to Part One and Part Two of the Tax Code of the Russian Federation and article 3 of the Federal Law "On amendments being made to Part One and Part Two of the Tax Code of the Russian Federation". The Law has introduced modifications into the Tax Code of the Russian Federation relating to the rules of taxation of controlled foreign companies (CFC), tax residence, tax implications of voluntary declaration of property and accounts by individuals, symmetrical corrections for taxation of controlled transactions, as well as a threshold modification of the cost value of capital and depreciable assets.
Yuriy Ivanov, Head of Tax practice
8
April
2015

Changes in the timelines and procedures for declaring foreign organizations and structures

On 6 April 2015, Russian President Vladimir Putin signed Federal Law No. 85-FZ (hereinafter the “Law”), which, in addition to changing provisions on social tax deductions on personal income tax, changes the procedure for notifying the tax authority on the presence of foreign organizations and structures.
Yuriy Ivanov, Head of Tax practice
10
November
2014

Tax monitoring will reduce tax risks

On 04 November 2014, signed was Federal Law No. 348-FZ “On Amendments to the Tax Code of the Russian Federation”. The law provides for the possibility of applying tax monitoring, which is carried out at the location of the tax authority, in relation to taxpayer organizations (payers of fees and tax agents). (This legal update is available only in Russian)
Yuriy Ivanov, Head of Tax practice
27
October
2014

The new procedure for launching criminal cases involving tax crimes. Comprehensive analysis

On 22 October 2014, Federal Law No. 308 “On Amendments to the Criminal Procedure Code of the Russian Federation” was signed and entered into force, which amended the procedure for launching criminal cases involving tax crimes under Articles 198-199.2 of the Criminal Code of the Russian Federation. (This legal update is available only in Russian)
Yuriy Ivanov, Head of Tax practice
11
April
2014

Tax Convention with Malta is ratified

Russian President Vladimir Putin signed the law on the ratification of the Convention for the avoidance of double taxation with Malta. (This legal update is available only in Russian)
Yuriy Ivanov, Head of Tax practice
25
March
2014

Anti-offshore draft bill

On 18 March 2014, the Ministry of Finance of Russia published for discussion a key “Anti-offshore” draft bill, which introduces significant changes to the taxation of profits of controlling foreign companies. (This legal update is available only in Russian)
Yuriy Ivanov, Head of Tax practice
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