Update - Further Amendments to Russia's Proposed CFC Rules

On 26 June 2014, additional amendments to Russia's proposed CFC rules introduced earlier this year were published. This is the third draft of the rules.

The main changes include:

• The threshold for determining if a taxpayer is a controlling person is increased from 10% to 50% direct or indirect participation, solely or together with related parties
• Additional situations where a foreign organization will be excluded from being characterized as a CFC include:
  • Companies taking part in governmen…