Together with the introduction of the new CFC lump-sum tax regime, new rules of the CFC reporting and liability for non-compliance with such rules will be imposed on the CFC controlling persons applying general CFC taxation regime. Indeed, the controlling persons will be liable to file with the tax authorities the documents confirming the amount of the CFC’s profit/loss (financial statements, accounting statements, auditors’ reports, etc.) as indicated in the CFC notification. At present, such documents shall be presented only at the tax authorities’ request. The fine for non-submission of these documents will increase to 500K rubles as compared to actual amount of 100K rubles. The fine for non-submission of the CFC notification will also increase to 500K rubles (instead of actual 100K). Tax authorities will be authorized to request additional documents confirming the CFC’s profit/loss or exemption. If the controlling persons fail to provide the requested documents translated into Russian within 1 month, they may be exposed to a fine in the amount of 1M rubles.
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NAZALI TAX & LEGAL |