Amendments to the List of states and territories providing preferential tax treatment and (or) not providing for disclosure and provision of information during financial transactions (offshore zones) were introduced by Order of the Ministry of Finance of the Russian Federation No. 86n dated June 5, 2023.
According to the position of the Ministry of Finance of Russia, stated in the letter dated November 1, 2023, N 03-08-13/104225, the provisions of the Order in terms of expanding the list to states (territories) that were not previously included in it, shall apply from January 1, 2024.
In this regard, it is noted that the provisions of the Order of the Ministry of Finance N 86n cannot be applied to transactions, income and (or) expenses on which are recognized in 2023 (regardless of the date of conclusion of the relevant contract), in order to recognize such transactions as controlled in accordance with subparagraph 3 of paragraph 1 of Article 105.14 of the Tax Code of the Russian Federation.
Document: Letter of the Federal Tax Service of Russia dated January 23, 2024, N ШЮ-4-13/620@ “On Sending a Letter from the Ministry of Finance of Russia” (together with Letter of the Ministry of Finance of Russia dated December 27, 2023, N 03-12-11/1/126454).
According to the position of the Ministry of Finance of Russia, stated in the letter dated November 1, 2023, N 03-08-13/104225, the provisions of the Order in terms of expanding the list to states (territories) that were not previously included in it, shall apply from January 1, 2024.
In this regard, it is noted that the provisions of the Order of the Ministry of Finance N 86n cannot be applied to transactions, income and (or) expenses on which are recognized in 2023 (regardless of the date of conclusion of the relevant contract), in order to recognize such transactions as controlled in accordance with subparagraph 3 of paragraph 1 of Article 105.14 of the Tax Code of the Russian Federation.
Document: Letter of the Federal Tax Service of Russia dated January 23, 2024, N ШЮ-4-13/620@ “On Sending a Letter from the Ministry of Finance of Russia” (together with Letter of the Ministry of Finance of Russia dated December 27, 2023, N 03-12-11/1/126454).