4 april 2018

Three-level documentation of international groups of companies

Amendments to the Russian Tax Code introduced by the Federal Law dd 27.11.2017 No 340-FZ have imposed an additional disclosure obligation on participating companies of international holdings.

In addition, the Tax Code is amended with provisions on the international automatic exchange of country reports in accordance with international treaties of the Russian Federation, which implies broad access of Russian tax authorities to information provided by foreign companies that are part of the same group as Russian taxpayers.

The adopted amendments stipulates a significant amount of information to be disclosed to the tax authorities.

These innovations will require additional attention from taxpayers to the study of documents provided by both Russian and foreign participants of international groups of companies and the language used in such documents.

Before disclosing the relevant information, we recommend conducting an assessment of the associated tax risks independently or with the involvement of outside consultants.

More details about this you may find in the attached presentation.