Update on legislative developments in Russia: governmental de-offshoring initiatives and proposed new CFC and tax residency rules

When it was first revealed by president Vladimir Putin a few years ago that the offshore-backed modus operandi for the Russian economy could no longer be tolerated, very few could have predicted that the government would be making a serious legislative effort to fight the offshore structures that had essentially crippled all industry sectors in Russia, both public and private.

Why does Russia need it? In his message to the Federation Council delivered on 12 December 2012, president Putin had particularly focused on the need for de-offshorisation: ‘Our entrepreneurs are often reproached for being unpatriotic. The offshore nature of Russia’s economy has become a household word. Experts call this escaping the jurisdiction. According to some estimations, nine out of every 10 major deals by large Russian companies, including the state-owned ones, are not subject to national laws. We need a whole system of measures for the de-offshorisation of our economy. I order the government to submit appropriate comprehensive proposals on the subject.’

In his next 2013 annual speech at the Federation Council, president Putin had followed up by saying: ‘Last year in my address, I talked about the goals underlying the de-offshorisation of the economy…

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