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In recent years, the intensification of sanctions pressure has led to active business restructuring and the transfer of assets (shares, stakes) between companies, as well as beneficiaries of Russian groups. In these cases, the parties often set a nominal value for such transactions.
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If a foreign company sells shares (shares) of Russian organizations, more than 50% of whose assets directly or indirectly consist of real estate located in Russia, tax is withheld at source. In this case, the tax is withheld at the full rate (20%), since from 8 August 2023, all double taxation agreements with unfriendly countries have been suspended.
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The Central Bank of the Russian Federation (CBR) has decided that until the end of 2023 the total cost of credit (TCC) will not be limited for all categories of consumer credits, as well as certain types of loans.
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If income in the form of interest is paid to export credit agencies or banking organizations in unfriendly countries, tax agents are entitled to continue not to calculate and not withhold income tax on such interest income (or withhold it at a reduced rate).
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Amendments were made to the Tax Code of the Russian Federation, which established personal income tax rates for employees working remotely for Russian employers and who have lost the status of a tax resident of the Russian Federation at the level of 13% and 15%.
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Effective August 1, 2023, the UAE became subject to new tax regulations established by Cabinet Decision No. 74 of 2023 "On the Executive Regulations of Federal Decree-Law No. 28 of 2022 on Tax Procedures" ("Decision No. 74") and Cabinet Decision No. 75 of 2023 "On the Administrative Penalties for Violations Related to the Application of Federal Decree-Law No. 47 of 2022 on Taxation of Corporations and Businesses" ("Decision No. 75").
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On June 7, 2023, Russia and Oman signed an Agreement for the Avoidance of Double Taxation and the Prevention of Tax Evasion on Income. According to the statement of the Ministry of Finance of the Russian Federation, the ratification of the Agreement is expected to take place by the end of this year.
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These agreements may be suspended by a presidential decree. In this case, the application of reduced withholding tax rates (tax exemptions) in respect of income subject to the agreements will be suspended from the moment the relevant decree is issued.