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Newsletter

Cypriot Investment Scheme
Repossession Property Yield Properties

Latest news

  • 9 October 2019 Landmark Agreement between Cyprus and the United Kingdom

    FULL details of the landmark agreement between Cyprus and the United Kingdom... read more

  • 3 October 2019 Breaking News Potential Change to Definition of Russian Tax Residency for Individuals

    Individuals spending 90 days a year in Russia, or having their centre of... read more

  • 10 September 2019 Many Home dwellers few are the first borrower applications

    Implementation of the Home plan has not begun with the best odds, as... read more

  • 3 September 2019 Home plan from tomorrow for 10 thousand borrowers

    After months of discussions, the Home Plan is being implemented from tomorrow... read more

  • 2 September 2019 July property sales hold steady Update

    The number of Cyprus property sales during July was the same as the number... read more

Cypriot Investment Scheme
Repossession Property Yield Properties

Latest news

  • 9 October 2019 Landmark Agreement between Cyprus and the United Kingdom

    FULL details of the landmark agreement between Cyprus and the United Kingdom... read more

  • 3 October 2019 Breaking News Potential Change to Definition of Russian Tax Residency for Individuals

    Individuals spending 90 days a year in Russia, or having their centre of... read more

  • 10 September 2019 Many Home dwellers few are the first borrower applications

    Implementation of the Home plan has not begun with the best odds, as... read more

  • 3 September 2019 Home plan from tomorrow for 10 thousand borrowers

    After months of discussions, the Home Plan is being implemented from tomorrow... read more

  • 2 September 2019 July property sales hold steady Update

    The number of Cyprus property sales during July was the same as the number... read more

Breaking News Potential Change to Definition of Russian Tax Residency for Individuals

Individuals spending 90 days a year in Russia, or having their centre of vital interest in Russia, might be viewed as Russian tax residents starting from January 1, 2020.

   

This was announced on the 30th of September in the draft of the Russian Tax Policy Program 2020-2022.

The Tax Policy Program is not a law and is not implemented directly. For the new definition of tax residency to apply for year 2020, the law would have to be passed by the end of November 2019. 

Many Russian businessmen distrust their government and prefer to keep money and other assets abroad.

De-offshorisation measures made foreign structures of Russian owners taxable in Russia through introduction of CFC legislation and management and control test. Signing up to AEOI/CRS and starting exchanging information with foreign tax authorities made non-compliance with Russian legislation apparent to the Russian tax authorities. 

However, tax residency definition of a generous 183 days a year meant that many businessmen could run their Russian empires without triggering Russian residency test. UK, Monaco, Cyprus, Malta, Dubai, Switzerland, Italy and Portugal are a popular choice for Russian non-tax residents with significant ties to Russia. 

Should the proposed change be implemented, many wealthy Russians will become Russian tax residents and will have to pay Russian tax on world-wide basis and comply with Russian CFC requirements. 

There are still some practical solutions. To name just a few, one can successfully argue tie-breaker clauses in double tax treaties, set up non-CFC structures, or pass on wealth to children based in foreign jurisdictions and some others.  

Contact us so we can put you in contact with the relevant lawyers, who will be happy to advise you on the effect of the change on your overall tax burden and propose available solutions.