Month: November 2023
MTPP Workshop
PROGRAM
Implications for Transfer Pricing
Evgeniya Chernova
“Suspension of DTT and expansion of the list of offshore jurisdictions. Changes. Easing?
Comments. Consequences.”
Daria Pogodina
ABOUT THE SEMINAR
During her speech, Evgeniya Chernova highlighted how changes in tax regulation and the international situation affected the practice of transfer pricing in Russian and transnational companies. Particular attention was paid to new documentation requirements, changes in approaches to comparability analysis and increased control by tax authorities. The report was accompanied by examples from practice and caused an active discussion.
Daria Pogodina, within the framework of the topic, analyzed the current changes in the regulation of transactions with foreign related parties, the expansion of the list of offshore jurisdictions and their impact on taxation and the corporate structure of business. Comments were given on current regulatory documents, as well as recommendations for reducing risks and adapting to new conditions. The report generated increased interest among specialists in the field of international taxation.
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Expansion of the list of offshores. Softening. Comments. Consequences
Evgeniya Chernova gave a report on the topic “Expansion of the list of offshore jurisdictions. Mitigation. Comments. Consequences.” The speaker analyzed in detail the latest changes in the list of offshore jurisdictions, possible tax and legal consequences for Russian companies, as well as measures aimed at mitigating new restrictions. The report aroused the interest of participants working with foreign structures and international settlements.
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New conditions for obtaining permissions for transactions with shares of LLCs
In October 2023, the Russian Ministry of Finance published two updates at once on the conditions for obtaining permissions from the Government Commission for Control of Foreign Investments in the Russian Federation (hereinafter referred to as the “Government Commission”) to carry out transactions with shares of LLCs with the participation of persons from unfriendly countries included in the list, approved by the Order of the Government of the Russian Federation dated 05.03.2022 No. 430-р.
It concerns, first of all, the Extract from the minutes of the meeting of the sub-commission of the Government Commission dated 26.09.2023 No. 193/4, which states that now one of the conditions for obtaining permissions from the Government Commission to carry out such transactions is:
- the presence of an obligation to make a voluntary contribution to the federal budget in the amount of at least 15% of the market value of the relevant assets, indicated in a report on independent assessment of the market value of the assets.
Let us remind you that previously this condition sounded as follows[1]:
- the presence of an obligation to make a voluntary contribution to the federal budget within three months from the date of the transaction in the amount of:
- at least 10% of half of the market value of the relevant assets – if the assets are sold at a discount of less than 90% of the market value of the relevant assets, or
- at least 10% of the market value of the relevant assets – if the assets are sold at a discount of more than 90% of the market value of the relevant assets.
In addition, on 16.10.2023, the Application Form for granting permission to carry out (execute) a transaction (operation) or a group of transactions (operations) was updated. The application must now disclose the beneficial owners of all parties to the transaction, not just the applicant’s party.
The remaining conditions for obtaining permissions from the Government Commission to carry out transactions with shares of LLCs with the participation of persons from unfriendly countries can be found here.
We will be happy to answer your questions!
[1] Subclause 4 of clause 1 of the Extract from the resolution of the sub-commission of the Government Commission dated 07.07.2023 No. 171/5 is declared invalid.
Contacts:
Maria Matrossowa
Yulia Belokon
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