Dear Clients and Associates,

please note that due to celebration of New Year and Christmas our offices will be closed as follows:

  • Larnaca: 25,26,31 December 2015 and 1,2,6 January 2016 – public holidays
  • Moscow, Kyiv, St.Petersburg - from 31 December 2015 till 10 January 2016 (inclusive)  – public holidays

We wish you a Merry Christmas and a Wonderful Happy New Year 2016!


Ukraine and Cyprus have signed the Protocol to amend the Convention for the avoidance of double taxation between the Governments of both countries. The redrafted Convention has been prepared with due consideration of the guidelines provided by the Organization for Economic Cooperation and Development.


The Federal Tax Service of Russia (FTS) has published a draft Order on «Approval of the List of states and territories which do not ensure information exchange for taxation purposes with the Russian Federation” on the official website, in other words, a “black list” of the countries which are referred to by the Tax Code of RF with regard to tax exemption of the profit of the controlled foreign companies (CFC) in RF.


The RF Ministry of Finance in conjunction with the Singapore party has prepared draft amendments to the double taxation avoidance agreement between Russia and Singapore. The text of the amendments has been published at the Federal portal of legal act drafts and currently undergoes expertise. 

The draft specifies certain criteria for acknowledgement of permanent representation and provides for more attractive dividend, interest and royalty taxation terms, at large. It is clearly specified that debenture interest is exempted from taxes at the source of payment.

It is specifically pointed out that the provisions of this agreement are not applicable in those cases where it is proved that the receipt of the associated benefits is the basic purpose of this or that transaction.

The amendments to the section regarding the exchange of financial information are not revolutionary ones and are designed, in broad terms, to bring the old version of the agreement into conformity with the up-to-date requirements of the international data exchange standards for tax purposes.    


A public reading of the bill stipulating liability of individuals for failure to comply with the procedure of submitting records on cash flow on accounts (deposits) held in foreign banks commenced on August 12, 2015 in RF.  

The bill “On introduction of changes into article 15.25 of the RF Administrative Offence Code” developed by the RF Ministry of Finance initiates the different rates of penalty depending on the length of delay.  It should also be noted that the penalty can be imposed on each failure to submit (i.e. per each quarter, on each account). 

The amendments to the Law are assumed to become effective from January 1, 2016 following the adoption of the respective Governmental decree regulating the procedures for enforcement of new standards in more detail.   


The UAE Government is currently drafting a bill on introduction of a sales tax (VAT) in the country. The precise tax rates are not known yet; however, according to the preliminary information, FMCG goods are assumed to be exempted from taxes while top-end goods, tobacco products and alcoholic beverages will be taxed at a higher rate.


On Wednesday, May 20, 2015, RF State Duma passed in its second reading a capital amnesty bill (Bill “On voluntary declaration of property and bank accounts (deposits) by the individuals”).


On April 30, 2015, the Federal Tax Service of RF explained on its official website that currently the individuals – residents of RF are not liable of submitting cash flow statements for their bank accounts outside the territory of the Russian Federation since no form of such statement and the related submission procedure in respect of the individuals has yet been approved.    

It should be noted that such form and the related submission procedure in respect of the legal entities have already been in place and governed by the RF Government Decree No.819 as of 28.12.2005.   


A governmental bill on capital amnesty was brought to the State Duma on March 27, 2015. According to Anton Siluanov, RF Minister of Finance, the assets subject to declaration within the scope of capital amnesty shall be exempt from nonrecurring taxes, duties and charges.


On the 24th of February 2015 the Seychelles has become the 85th member-participant to join the Convention on Mutual Administrative Assistance in Tax Matters.     

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