Tax Alert about Deoffshorization in Russian Federation from EY (17 February 2015)

By | 15.11.2015

Tax Alert from Ernst & Young dated 17 February 2015 “Deoffshorization in action: A fast developing practice”.

Analysis of several recent court cases to illustrate the practical approaches and methods that the Russian tax authorities are already applying to structures with an international component (Equant LLC case, Sunrise Tour LLC case, Avtotor Management case, Oriflame Cosmetics LLC case). Issues: royalties, withholding income tax from the source in Russia, beneficial ownership concept, permanent establishment of foreing legal entity.

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