Articles by Dzhangar Dzhalchinov



B2B: Recent Amendments and the Threat of Criminal Prosecution to Combat Tax Avoidance

  • 23 February 15
  • Dentons
Amendments made by Federal Law No. 308-FZ of October 22, 2014 established a new procedure for initiating criminal cases in tax-related offenses (art. 198-199.2 of the RF Criminal Code).

B2B: Tax Risks and Tax Opportunities

  • 02 February 15
  • Dentons
Without a doubt, 2014 can be regarded as a turning point in the development of tax law relations: taxpayers moved from a conservative approach in matters of taxation to a moderately aggressive one, seeking out further opportunities to fund their activities from tax overpayments, and making use of tools to reduce tax risks.

B2B: Finance Ministry Moves to Fight Abuse of Double Taxation Agreements

  • 19 May 14
  • Dentons
On April 9, 2014, the Finance Ministry issued guidelines on the application of agreements on the avoidance of double taxation (DTAs), which requires tax agents and tax authorities to conduct an assessment of whether foreign recipients of income in Russia have the right to apply a tax exemption in Russia or a lower tax rate.

B2B: Swing High, Swing Low

  • 10 December 13
  • Dentons
Rules for controlled companies, expansion of legal entity residency and beneficial ownership concepts Е It certainly will not be "boring."

B2B: Rearming the Tax Authorities

  • 21 May 13
  • Dentons
The tax authorities are continuing to use a blunt instrument approach to some issues, though the scalpel was invented long ago.

Avoiding Truisms

  • 13 November 12
  • Salans
Rumor had it that in the spring of this year, a draft law on the regulation and taxation of cost sharing agreements between affiliates was to be introduced in the State Duma. These concepts arrived in Russia along with foreign investments, but the soil was unprepared. We are now approaching winter and the rumors remain only rumors.

Big Brother Is Watching You

  • 29 May 12
  • Salans

The Russian government cannot ignore the fact that Russia's investment climate is far from ideal. In January-April 2012, $42 billion left Russia. Last year, net private capital outflows from Russia totaled $80.5 billion.

Justified Expenses: Staying Within the Mark

  • 08 November 11
  • Salans

Before carrying out a transaction, it is important to check the tax consequences. Ignoring the tax aspects may result in a seemingly desirable deal turning out to be somewhat less attractive once the tax costs of a poorly structured transaction become apparent. One such tax aspect is deductibility of expenses for the purposes of profit tax.

Remedies Against Tax Surrealism

  • 19 July 11
  • Salans

Even if a tax audit results in the tax authority having complaints concerning wrongly calculated taxes and those complaints are essentially justified, additional tax assessments, late payment interest and fines are still not inevitable and the taxpayer should not voluntarily part with its money.

A Fly in the Ointment

  • 10 May 11
  • Salans

We have already become used to record-breaking numbers of amendments to Russian tax law. Legislators are rewriting rules, articles and sometimes even entire chapters of the Tax Code, and consequently changing the rules of tax behavior. If the objective is to promote greater clarity, then lawmakers' efforts should be applauded.

Defense Against Repeat Audits

  • 07 December 10
  • Salans
Tax audits are never the most pleasant experience for taxpayers, irrespective of how УcleanФ they may be. Any tax audit will create additional burdens on taxpayers going about their normal business activities as they put up with the tax authoritiesТ actions.