Russia Clarifies Effective Date of New GAAR Provisions for Court Cases involving Tax Audit Decisions

Russia's Federal Tax Service recently published guidance letter No. SA-4-7/23972 concerning the application of the country's new general anti-avoidance rule (GAAR) provisions introduced by Federal Law No. 163-FZ of 18 July 2017 ({News-2017-07-28/A/4-previous coverage}). The letter notes that new GAAR provisions may not be applied by the courts in considering cases challenging tax authority decisions in relation to tax audits made before the entry into force of Law No. 163-FZ, which was 19 Au…