Media & Resources

Tax authorities are to extend conduit companies criteria

DATE: May 26, 2017 | AUTHOR: atlawyers

The media highlighted RF tax authorities’ initiative to expand a statutory test of a ‘conduit company’, i.e., a foreign entity which is not a beneficial owner of income. Such companies are not entitled to claim benefits under DTTs. New criteria may include lack of business activity, restrictions to dispose of income and/or obligations to transfer income to offshore jurisdictions. Previously, the RF Ministry of Finance has already commented on this matter.

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