Arts and Life
Mothers & Daughters
Arts and Life
Articles by Boris Bruk
B2B: The G20 BEPS Initiatives: Enforcement of Taxation Will Get Harder
The G20 countries are no longer satisfied with the abilities of their tax administrations to detect tax planning arrangements.
B2B: The Power to Tax Is the Power to Destroy
Although the use of anti-abuse language has become routine in the court room, some insight can be gained from recent rulings.
Do Russian Arbitration Courts Endorse Aggressive Tax Planning?
In 2012 Russian arbitration courts ruled on several cases that may be considered landmarks in the fight against allegedly abusive tax schemes.
The Court Halts One Step Before Application of the Beneficial Ownership Concept
On Aug. 29, 2012, the Moscow Arbitration Court made a noteworthy ruling in the Eastern Value Partners Limited (Decision of the Moscow Arbitration...
The Naryanmarneftegaz Case: An Expansion of Russian Thin Capitalization Rules?
Following the recent pronouncement by the Supreme Arbitration Court of the Russian Federation on the Severny Kuzbass case, which was in the spotlight...
Court Decision Rocks Intragroup Finance Practice
In early January, the Russian Federation's Supreme Arbitration Court published Presidium Ruling No. 8654/11 in the case of OAO Coal Company Severny...
New Transfer Pricing Rules: Information Issues
Russia has recently adopted rules on transfer pricing that, despite their considerable detail, have left a number of practical questions unresolved...
Elimination of Double Taxation in Russia: Practical Issues
Elimination of double taxation suffered by Russian companies carrying out cross-border activities is one of the cornerstones of the Russian tax system...
Beneficial Ownership Is a Big Factor in International Tax Planning
When taxpayers gain access to double taxation treaty benefits in situations where they were not expected to gain such access, the technical term used by...