Article 54.1 of the Tax Code of the Russian Federation has proven highly controversial
Article 54.1 of the Tax Code of the Russian Federation has proven highly controversial. Recent statistics show that taxpayers only won 75 cases (out of 1,013) and had claims upheld in part in 140 cases. On March 10 2021, the Federal Tax Service (FTS) issued Letter No. BV-4-7/3060@ to clarify how the article should be applied.
The Letter states that previous approaches to settling unjustified tax benefit disputes still apply under Article 54.1. In addition, the state budget must be suffering a ‘damage’, and the actual tax liability of a taxpayer in a tax audit must be calculated (via tax reconstruction, inter alia, by accounting the taxes paid under the simplified tax regime when splitting business cases are considered). The notion of due care and diligence is restated as a precondition for a taxpayer to be relieved from tax claims.
Историк Дмитрий Юрков: У любого подземного спецобъекта всегда есть секреты, и секреты эти обычно связаны с тем, что мы просто не всё знаем | Программа: Большая страна | ОТР
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Предъявлены обвинения полякам, которые держали в неволе выходца из СССР
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State Duma ratifies denouncement of tax agreement with Netherlands
MOSCOW. May 11 (Interfax) - The State Duma at a session on Tuesday voted to terminate the agreement on avoidance of double taxation with the Netherlands.
It was reported earlier that Russia had held several rounds of negotiations with the Finance Ministry of the Kingdom of the Netherlands on amending the agreement in terms of increasing the withholding tax rate on dividends and interest to 15%. Russia proposed terms corresponding to those already coordinated with Cyprus, Luxembourg, and Malta; however, the negotiations were unsuccessful. The existing tax agreement with the Netherlands envisages fairly attractive tax conditions and makes it possible to withdraw profit from Russia with tax payment at an effective rate of 2-3%, while the corresponding rate in Russia is far higher - for example, for legal entities, 15% on dividends and 20% on interest, the Finance Ministry said in a letter.
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Russia has introduced reduced pension and social
insurance contribution rates for IT and technology companies, in
addition to the reduced rates introduced in April 2020 for SMEs.
This article provides details.
To create the most favourablepossible environment for
the intensive development of IT industry and pooling resources for
the new projects, the Russian
Government has adopted aLaw (Federal Law dated
31 July 2020 N 265-FZ On amendments to the part two of the Tax
Code of the Russian Federation ) introducing a number
of changes and tax incentives for the IT and