Last year, for the first time the courts gave a legal evaluation
to the deductibility of interest on debt obligations arising
due to a company's participation in a cash pooling system,
which is understood to be a system for managing available cash on
the bank accounts of companies controlled by major multifunctional
holdings that have an extensive network of branches, structural
subdivisions or subsidiaries.
In particular, in April 2016 the Arbitration Court of
Chelyabinsk Region recognized economically justified a system of
revolving loans existing under cash pooling agreements concluded
between Gazprom Neft LLC, its subsidiaries and credit organizations
(the Gazprom Neft Chelyabinsk LLC case, No.
А76-15351/2015).
It follows from that judicial act that the tax authority's
claims to Gazprom Neft Chelyabinsk LLC (the "Company"),
which is a wholly-owned subsidiary of Gazprom Neft OJSC (the
"Parent C
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8 May 2018, Speaking Engagement, Singapore, Singapore
New political narratives are transforming international trade and global integration. Even the most ardent supporters of trade liberalization recognize that these political realities and the need to account for sustainable development, inclusive growth and managing the digital revolution will radically shape the landscape of international trade.
New political narratives are transforming international trade and global integration. Even the most ardent supporters of trade liberalization recognize that these political realities and the need to account for sustainable development, inclusive growth and managing the digital revolution will radically shape the landscape of international trade.
The Dentons Rodyk Dialogue brings together an exciting line up comprising Canada’s former Prime Minister, Mr. Stephen Harper, world-renowned international trade expert from Melbourne University, Professor Tania Voon and Singapore’s leading thinker and entrepreneur, Mr. Ho Kwon Ping to discuss the future directions of international trade in the age of Brexit and Trump.
Please plan to join us at our annual Denver Government Contracts Briefing. As in previous years, the complimentary and exclusive meeting will cover the latest developments in the government contracting industry.
CLE credit has also been applied for in California, Illinois, Nebraska and Texas. (CLE credit approval is pending. CLE credit hours may vary by state.)
On April 6, 2018, there will be an important change to the way termination payments are taxed in the United Kingdom. New tax rules, which aim to simplify the taxation of termination payments ...
In recent years, HMRC has increasingly targeted the 'disguised employment' of self-employed people. Its clampdown is targeted at individuals supplying their services ...
On 31 January 2018, the same legislation that brought into force the two new corporate offences of failing to prevent the facilitation of tax evasion in September 2017 ...
Now is the time to act if you may have offshore assets or income for which you haven't fully declared your UK income tax, capital gains tax or inheritance tax liabilities.
You probably know that when operating in a diverse global market, knowing and understanding the local requirements for financial compliance could make the difference between the success...
On 19 February 2018 the President of Russia signed three federal laws which extended the capital amnesty campaign and timeframes for tax-exempt liquidation of foreign companies and unincorporated structures.
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