Tax News

Treaty between Russia and Cyprus-Russian MoF clarifies dual tax residence status of individuals

On 19 September 2018, the Cypriot Tax Department issued an announcement clarifying that Constituent entities with a Cypriot Ultimate Parent Entity (UPE) will not be subject to local filing in their jurisdiction of tax residency, given the relevant CbC Multilateral Competent Authority Agreement (MCAA) is activated between Cyprus and the other jurisdiction. 

CY-Russia - Thin Cap Rules

The Russian courts issued a decision on 6 March 2018 (case OJSC SUEK-Kuzbass) on the application of the Double Tax Treaty between Cyprus and Russia of 1998 as amended in 2010 (the ‘DTT’). Based on the decision interest expense was considered as non-tax deductible in accordance with the Russian thin capitalization rules.