Remains the fact that the offshore companies are widely used in the Russian business for tax planning, however till now there is a considerable uncertainty of a legislative and judicial estimation of such use.
Also at a jurisdiction choice it is necessary to consider the purposes for which the company will be used in Russia. They can be rather various. For some of these purposes (account opening in the Russian bank, accreditation and statement on the account in foreign mission tax department in the Russian Federation, real estate registration) is necessary reception of the tax certificate in the country of registration of the company and its granting in the authorized state structures of the Russian Federation. In this case suitable jurisdictions are Cyprus, and also other countries providing statement of the companies on the tax account and delivery of corresponding certificates.
Features of fulfillment of payments from Russia in favor of the non-resident.
At fulfillment of payments on behalf of the Russian organizations in favor of the non-resident (including the offshore company) it is necessary to consider norms of the tax right.
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