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Significant changes to Russian tax legislation due in 2012

Overview

From 1st January 2012, Russia will undergo several key changes to its tax legislation. Firstly, the new Transfer Pricing Law significantly changes the existing TP regulations in Russia. Under the new Law, there is no longer requirement that, to be subject to TP control, the price applied by the taxpayer must deviate by more than 20 per cent from the fair market price.


The Law on tax consolidation allows a consolidated taxpayer to be created from a number of individual taxpayers in the same group of companies. The main thinking behind this Law is to allow the members of a consolidate group to offset income against the losses of the other members.


Lastly, the Russian Government has recently started to renegotiate Russia's Double Taxation Treaties by singing Protocols to certain DTTs. So far, following on from the Protocol with Cyprus which was signed last year, Protocols with Switzerland and Luxemburg were signed this autumn.


In this briefing, Pepeliaev provides a brief overview of each of the legislation changes, the reason behind them and how they are likely to affect businesses and organisations.


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