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With the entry into force of Federal Law No. 376-FZ on 1 January 2015, the maintenance of business activities in low-tax jurisdictions may end up becoming unbeneficial tax-wise for Russian taxpayers. This law notably introduces to Russian tax legislation the concepts of controlled foreign companies and of beneficial ownership, as well as tax residency criteria for legal entities.
Even though the resulting changes are primarily aimed at limiting the use by Russian taxpayers of low-tax jurisdictions in tax optimisation schemes, these amendments are also expected to influence the activities of foreign SPVs which are in partnership with Russian residents.
As a result, it is highly likely that this development will lead a number of CFC owners to consider reorganising the corporate structure of their businesses.