On 27 May 2014 the Russian Ministry of Finance published a revised draft of amendments to the Tax Code of the Russian Federation, introducing controlled foreign corporation (CFC) regulations, “thin capitalization rules” and the concept of “effective place of management”. In addition, a “beneficial owner” definition is introduced for the purposes of applying tax treaties.
The revised draft will be submitted to Russian Parliament for legislative procedures. It is however likely the proposed legislation will undergo further amendments. If adopted, the proposed amendments to the Tax Code will likely enter into force as per 1 January 2015.