Russia: “De-offshorization law,” investment structuring | KPMG | GLOBAL
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Russia: Tax provisions in “de-offshorization law” and investment structuring

Russia: “De-offshorization law,” investment structuring

Measures in Russian tax law need to be considered in structuring investments to or from Russia.


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Specifically, measures in the so-called “de-offshorization law” aim to prevent the use of offshore companies and unincorporated foreign structures—for example, funds, partnerships, trusts, other forms of collective investment vehicle and/or trust management—for tax planning purposes. The “de-offshorization law” introduced the following concepts into Russian tax law:

  • Controlled foreign company (CFC)
  • Beneficial owner
  • Tax residency for companies
  • Taxation of capital gains realised from the sale of “property-rich” companies


Read a November 2016 report prepared by the KPMG member firm in Luxembourg

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