«Tax Policy and Tax Disputes – 2025»
The Pravo.ru conference «Tax Policy and Tax Disputes – 2025» was held on September 30th.

KKMP Partner Alexander Anichkin spoke at the session “Tax Disputes and Business Strategies: Risks, Compliance and Efficiency” with a report titled “Peculiarities of Taxation when Using Personal Funds with Foreign Assets.” Specifically, during his presentation, Alexander highlighted:

 

  • sanctions and counter-sanctions aspects that must be considered when structuring ownership of foreign assets through personal funds

  • the problems of qualifying certain types of income that a personal fund may receive from foreign assets for the purposes of calculating the share of “passive income”

  • the procedure for notifying about CFCs (Controlled Foreign Companies) included in the assets of a personal fund

  • the impact of undistributed profits of CFCs on the calculation of the share of “passive income” in the total income of the personal fund

  • the impact of cross-border transactions with digital currencies on the possibility of a personal fund using a reduced corporate income tax rate.

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