RUSSIA

Egorov Puginsky Afanasiev & Partners

"The best choice for solving multilevel issues with a marked Russian character"

Chambers Global
← back to contents
Moldova Moldova Moldova Moldova Moldova

40/4 Bol. Ordynka

Moscow, 119017

Tel: +7 (495) 935-8010

Fax: +7 (495) 935-8011

22-24 Nevsky pr.,Suite 132

St.Petersburg, 191186

Tel: +7 (812) 322-9681

Fax: +7 (812) 322-9682

3 Gough Square

London EC4A 3DE

Tel: +44 (0) 20 7822-7060

Fax: +44 (0) 22 7353-5905

www.epam.ru

RUSSIA: TAX COMPASS 2011

Corporate income taxation
Corporate Tax 20%
Dividends 9%(for residents)
Participation Exemption
  • Available only for corporations - tax residents
  • Shareholding: at least 50%
  • Holding duration: at least 365 days
  • N/A for dividends from black-list offshores
0%

Capital gains (new rule since 2011) – only for tax residents

  • Generally applicable for non-listed stocks
  • Special rules for listed stocks
  • Applicable for participation interest in Russian corporations
  • General condition - holding duration at least 5 years starting from 2011
 0%
Deduction of Interests
General limitation threshold (comparability principle as an alternative)
Central Bank based Refinancing Rate (CB-Rate)
  • For ruble Loans
  • For foreign exchange Loans


CB-Rate + 80%
CB-Rate – 20%
Thin Capitalization Rules
  • Debt/Equity ratio
  • For Banks/Leasing Companies

3/1
12.5/1
Depreciation
  • Premium available (for certain assets)
  • Accelerated depreciation (for certain assets)
 Linear/nonlinear
30%
max. index: 3
Transfer Pricing Rules
Methods: Comparable Market Prices; Resale Price; Cost plus; Transaction Net Margin Method; Profit Split Method 		New rules - 2012
Loss carried forward
Loss carried backward
Special rules for securities and financial instruments – separate basket		 10 years
N/A
Fiscal unity/Tax consolidation N/A
Withholding taxation
Withholding tax rate for dividends 15%
Interests, royalties 20%
Capital gains from real estate/real estate companies 20%
Double Tax Treaty Network (over 60 DTTs): reduction /elimination of WTH taxation
Personal Income tax
General flat rate 13%
Shareholder-Relief-System / Tax rate for Dividends
Exemption for capital gains from shares is under the same rules as for corporations 		9%
Inheritance tax N/A
Real Estate Transfer Taxes / Duty N/A
Value Added Tax
Standard / reduced rate    
Not applicable:

  • For small businesses/individual entrepreneurs under special (simplified) tax regime;
  • If quarterly net revenue < RUR2m (approx. EUR 50.000)
Exemption available for intangibles
Reverse Charge Method is available  		18% / 10 %
Property taxation
Corporations (average annual fixed assets’ value)

 max. 2.2 %
Individuals: residential property max. 2.0 %
Additional tax on Land max. 1.5 %
Severance Tax
On extracted minerals: gas, oil, metals, carbons etc.
Excises
On alcohol, tobacco, petroleum, autos (certain motorcycles)
Social Security Contributions
On annual salary up to RUR 415.000 (approx. EUR 10.375)
For Employer only 		34%
Incentives for Investors
Cluster principle (mostly): temporary tax reductions/exemptions
Special (simplified) tax regime
Available for small businesses / individual entrepreneurs 6 % (gross income) or 15 % (on income less expenses)
Advance (binding) tax rulings N/A
go to top