Kira Egorova, ALRUD Of Counsel, prepared an article about de-offshorisation of the Russian economy for the STEP Journal professional edition. In this review Kira describes the downward trend of the use of offshore structures in Russia.
In particular, there is detailed review of the Controlled foreign company (CFC) draft law, which provides the definition for CFC and beneficial owner. The draft law also includes the tax residency rules and penalties for CFC, the thin capitalization rules, the indirect sale of Russian real estate, the concept of tax residence for companies.
Kira Egorova draws attention to the fact that in light of the possible changes, new structures should be developed carefully and existing structures should be reviewed to determine whether reorganization of the structure is necessary.
This article is based on the second draft of the Controlled foreign company tax regulations.