Advice on taxation

The Federal tax service of Russia (hereinafter – the FTS) isn't staying away from the OECD trends aimed at transparency and combating abuse of rights (BEPS plan). This has a strong impact on the international transactions structuring and on holdings with subsidiaries in Russia.

The FTS’s initiatives in bilateral tax agreements are related to the "actual right to income" concept. As a result, tax disputes related to rule on the rights to use reduced dividends rates, interest and royalties paid in favor of "transit" parent companies are becoming more frequent. At the same time, the automatic CRS information exchange creates new opportunities for control over the international group’s cross-border transactions.

On the one hand, the transformation towards transparency and the lack of established practice require caution when planning international expansion in Russia, on the other hand this creates opportunities for building a long-term strategy under the clear game rules. We'll help you clear it up.

Areas of advisory services

  • Taxation of the foreign companies income received from sources in Russia
  • The application of agreements on double taxation treaties: exploring the applicability and source taxation
  • Transfer pricing. "Controlled" transactions of the affiliated companies
  • Obligations of foreign companies' Russian contractors to perform the functions of tax agents
  • Indirect taxation of cross-border and domestic transactions
  • Taxation of foreign investments and real estate
  • Free Investment zones


Aleksei Vlasov - regional manager
Phone: +7 9218761261