#4. Right After Me...

Dear readers,

I am so happy to see you reading the pages of our corporate edition titled
“Korpus Prava.Analytics”.

The subordinated loan in the Russian law was the focal point of our autumn edition. Our specialist Oskin Aleksey reviewed the legal regulation of the subordinated loans and compared the subordinated and traditional crediting. We will follow up on this topic, as the analysis of ongoing changes to the regulatory and legal framework proves the lawmakers’ clear intention to improve the regulation of the subordinated instruments in Russia.

In this edition we have consolidated the topical information for the accountants on the expected introductions and disputable situations happening with the taxpayers. The article by the auditor Svetlana Sviridenkova is a kind of an overview of the questions frequently asked by our readers and colleagues.

Certainly, we have not bypassed the issue of application of a concept of actual right to the income in the international tax relations, as it is still one of the most topical subjects in the tax practice.

Our specialists keep on focusing on the issues related to inheritance. Find and read in this edition the article on introduction of the inheritance fund institution in Russia in 2018, which is a reception from the foreign law institutions.

As before, we show respect for any criticism and suggestions from our readers, and any question or feedback from you is always welcomed. Please contact us in any suitable way and we will do as much as we can to take note of all your requests.

Artem Paleev
Managing Partner
Korpus Prava

CONTENTS
Roman Moskovskikh

Lawyer

Law and Tax

Korpus Prava (Russia)

On July 30, 2017 the law that came in force tightening the procedure for bringing controlling parties to subsidiary liability (Federal Law No. 266-ФЗ dated 29.07.2017).

Anna Senchenko, LL. M.

Leading Lawyer

Tax and Legal Practice

Korpus Prava (Russia)

Nowadays one of the most burning issues of the tax practice is the concept of an actual right to income in international tax relations. Recently, tax authorities carried out numerous tax inspections, which revealed illegal application of international treaties in cases when foreign companies are not qualified as actual income recipients.

Alexey Oskin

Deputy Director

Tax and Legal Practice

Korpus Prava (Russia)

Literally, the subordinated debt means a debt subordinated to other credits, which is ranked lower than other credits in case of debtor’s liquidation or bankruptcy.

Svetlana Sviridenkova

Deputy Director

Audit Practice

Korpus Prava (Russia)

Last summer brought a lot of questions on planned legal developments and taxpayer's actions in disputable situations.

Tatiana Frolova

Leading Lawyer

Korpus Prava Private Wealth

For some time now legislators have tried to attract personal savings to the securities market. It may be explained by the fact that Russian companies desperately need financial injections, but many of them have no access to the market of cheap foreign credits.

Vlada Shafirova

Onboarding Specialist

Corporate Services

Korpus Prava (Cyprus)

In late July 2017 Russian President Vladimir Putin signed a Decree "On Amendments to the Part 1, 2 and 3 of the Civil Code of the Russian Federation" with regard to establishment of a new institution in the Inheritance Law, the Inheritance Law Institution.