Taxation of cross-border structures and new exchange of information measures are two reasons why Russia’s new de-offshoring policy will have an impact on foreign as well as domestic groups, explain Estella Dzhantukhanova, Elena Solovyova, Alexander Krylov and Kateryna Grynova of Deloitte, Russia.
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The BEPS project has seen the arm’s-length principle shift its focus to where human activity takes place, but Leonard Wagenaar questions if this is sustainable in a financialised world
Anticipating potential changes in tax basis interpretations can help reduce audit risks in tax planning for intercompany equity transfers, says Abe Zhao of FenXun partners