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International Taxation
— 02.10.2024

International Taxation

In the era of globalization, international taxation has become a crucial topic for businesses and individuals conducting activities across multiple countries. In Russia, international taxation is regulated by the Russian Tax Code (RTC) and international double taxation avoidance agreements (DTAs). Proper tax consulting in this area enables the optimization of tax obligations and the reduction of risks.

Consulting on International Taxation

International income taxation involves aspects such as tax residency, tax rates, and obligations to the Russian Federal Tax Service (FTS). According to Article 7 of the RTC, if an international agreement provides different provisions than national legislation, the rules of the agreement take precedence. This is particularly important when taxing income earned abroad.

Double Taxation Avoidance Agreements (DTAs)

Russia has signed more than 80 DTAs with various countries, allowing taxpayers to reduce their tax burden. According to Article 312 of the RTC, taxpayers can apply reduced tax rates or exemption from taxation by providing the tax authorities with proof of their tax residency in another country.

Controlled Foreign Companies (CFCs): Accounting and Reporting

Individuals and legal entities that control foreign companies are required to submit CFC notifications and calculate taxable profits (Chapter 25 of the RTC). This includes:

  • Preparing and submitting CFC financial reports,
  • Filing CFC notifications with the FTS,
  • Calculating CFC profits and determining tax liabilities in Russia.

Taxation of International Income: Dividends, Interest, Royalties

Income from dividends, interest, royalties, and the sale of shares or equity stakes is subject to taxation both in Russia and abroad. It is essential to consider double taxation avoidance agreements and the provisions of Articles 208, 224, and 309 of the RTC.

Investment Strategy Development

Proper tax planning allows for effective investment in European countries, Southeast Asia, the Persian Gulf, and Turkey. Analyzing tax regimes and investment tools helps minimize tax costs and improve the efficiency of investments.

Conclusion

International taxation requires a comprehensive approach and professional support. Proper application of the RTC and international agreements allows taxpayers to reduce their tax burden and avoid reporting errors.