Russian taxation of CFC profits has been modified such that individuals are entitled to opt for personal income taxation on a deemed profit of a CFC. This note addresses the regime, focussing on situations in which CFC taxation would not be imposed.
Russian taxation of CFC profits has been modified such that individuals are entitled to opt for personal income taxation on a deemed profit of a CFC. This note addresses the regime, focussing on situations in which CFC taxation would not be imposed.