“Vedomosti”: under pressure from the EU, companies registered in the country will be allowed into the Russian ATS (SAR), which in connection with the provision of a number of benefits are called Russian offshores. Vedomosti writes about this with reference to several sources.
So far, only companies registered abroad have this right. It was assumed that through the SAR they would be able to return to the country. However, in Europe, such a regime is viewed as discriminatory towards Russian enterprises, and in order not to obtain the status of harmful tax regime, the government decided to follow the EU's lead.
Back in June of this year, the Council of the European Union included in his report the relevant thesis of the European Group on the Application of the Business Tax Code. In it, a number of claims were brought against the Russian ATS, and the refusal to register Russian companies became one of the main reasons for the pressure.
The interlocutor of the publication claims that the Federal Tax Service (FTS) is developing the changes, but they will be introduced to the government not earlier than another package of amendments concerning the CAP is adopted. In it, the authorities will try to give incentives to companies to form a real presence in offshores – this is an investment of at least 300 million rubles in infrastructure and an office with an area of at least 100 square meters with at least 15 employees.
In this case, they will be provided with additional benefits – the tax on capital withdrawal will be reduced from 15 percent to 10 percent, on profits to 5 percent, and on profits in the form of dividends – to zero. But only organizations with the status of an international holding company will be able to apply for special conditions.
Currently, there are two CAPs in Russia – on the Russky Islands in Vladivostok and Oktyabrsky in Kaliningrad. 52 companies managed to use the provided conditions, 47 of them chose Kaliningrad.
As one of the sources of the publication explained, the idea of the CAP arose exclusively in the context of the return of foreign companies with Russian roots, but it is impossible to ignore the remarks of the EU Council. Indeed, in the case of getting into the black list, the fiscal conditions that are applied in the country by the European Union will change, and this is fraught with serious losses.
As noted by Nikolai Milogolov, a leading researcher at the Tax Policy Center of the NIFI of the Ministry of Finance, if adequate amendments are adopted ATS will duplicate the regimes common in the EU countries. However, if the requirements are applied formally, then changes in legislation will not save Russia from being blacklisted.
Another source of Vedomosti spoke about such a possibility. One of the options for admission to the ATS of Russian companies may be the requirement to transfer real management procedures to the islands. However, in this case, he added, Russian companies are likely to abandon the idea, as it will damage the group's reputation and complicate management.
Earlier it was reported that the possibility of re-registration for the sake of tax cuts is being considered by Gazprom, “ Gazprom Neft, Alrosa, Severstal, Sberbank and VTB.