Russia Clarifies Recognition as a Controlling Person of a Foreign Company through a Listed Foreign Company

The Russian Ministry of Finance recently published a guidance letter concerning the recognition of a Russian taxpayer as a controlling person of a foreign company through a publicly listed foreign company under the controlled foreign company (CFC) rules.

The letter notes that, under the CFC rules, a Russian taxpayer is generally considered a controlling person if directly or indirectly owning more than 25% of the foreign company, or more than 10% of the foreign company if aggregate Russian …