Moscow, Russia

Russia: Tax Control Trends

By Irina Orlova-Panina, Nektorov, Saveliev & Partners

Russian tax authorities started to apply rules introduced in 2017 that establish the limits by which taxpayers can reduce their tax base. Now more efforts should be made by taxpayers to prove the “good faith” of their counterparties and business substance of the transactions. Taxpayers should proactively mitigate tax risks for previous and future tax periods.

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Moscow City International Business Center in Russia

Latest Developments on Beneficial Ownership in Russia

By Valeria Khmelevskaya, KBK Accounting

One of the major conditions currently necessary in Russia for application of the incentives provided by double taxation treaties (DTT) is the “actual right of the company to the income” obtained from the sources in Russia. This is the statutory naming for a beneficial ownership concept (BO) in Russia, which continues to develop and evolve after introduction into legislation in 2015.

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Chicago, USA

Tax Planning Spotlight: Qualified Small Business Stock

By Robert Jacobson, Kutchins, Robbins & Diamond, Ltd. (KRD)

Foreign nationals looking to start a business in the US often find that operating as a C Corporation is most desirable. One of the benefits of becoming a C Corporation is that they can issue Qualified Small Business Stock (QSBC). A QSBC is a US C Corporation that, upon sale, can have a 100% Federal capital gain exclusion for both regular and alternative minimum tax purposes.

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Rothenburg ob der Tauber, Germany

Regarding Non-Recognition of Profit Transfer Agreements: Infringement Proceeding Against Germany

By Brigitte Jakoby, Jakoby Dr Baumhof – Wirtschaftsprüfer Steuerberater Rechtsanwälte

On 25 July 2019, the EU Commission decided to initiate formal infringement proceedings against Germany regarding the non-recognition of profit transfer agreements which are in accordance with the laws of another EU member state. The background is that profit transfer agreements in Germany must be registered at the seat of the company. Furthermore, the contract must originally be concluded under German law – relevant to 291 AktG (Stock Corporation Act).

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Understanding Economic Substance

By Alun Griffths, Forward Group Limited

The Council of the EU adopted a resolution on a Code of Conduct for business taxation, the aim of which was counteracting the effects of zero tax and preferential tax regimes around the world. In 2017, the Code of Conduct Group (Code Group) investigated the tax policies of both EU member states and third countries, assessing:

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India an Attractive Investment Destination after Slashing of Corporate Tax Rates

By Bhavesh Jindal, Ashwani & Associates, Chartered Accountants

The history of the highest corporate tax rates in India goes back to 1997, with an effective corporate tax rate of 38.05%. However, in recent times, there has been a progressive shift in this trend, wherein India is becoming a more preferred nation for investment, bolstering investor sentiment by way of various regulatory and tax reforms. The central government, basing their optimistic approach on the main theme of “Made in India” as a means of nation building, has introduced a new tax regime, slashing the corporate tax rates in India by 8%, from the prevailing 30% to 22%. Even further, for a newly set up manufacturing company incorporated on or after 01 October 2019, the tax rates have been reduced to as low as 15%.

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