Special list of offshore jurisdictions for income tax purposes for 2024-2026 On April 27, the Order of the Ministry of Finance of the Russian Federation No. 35n dated 28.03.2024 was published. This order approves a special list of states and territories that provide a preferential tax regime for taxation and (or) do not provide for disclosure and provision of information when conducting financial transactions (offshore zones) in accordance with Article 4 of Federal Law N 595-FZ dated December 19, 2023.

In this regard, the new list of offshore companies applies to the tax periods 2024 – 2026:

  • for the purposes of exemption from profit taxation of controlled foreign companies in accordance with the third paragraph of Article 25.13-1 paragraph 7 of the Tax Code of the Russian Federation;
  • for adjusting the profit of controlled foreign companies in accordance with subparagraph 3, paragraph 1.2, item 1.2, Article 25.15 of the Russian Tax Code;
  • for determining the tax base for corporate income tax in accordance with paragraph three of subparagraph 11, paragraph 1, paragraph 1, Article 251 of the Tax Code of the Russian Federation;
  • for application of tax rates on profit tax of organizations in accordance with subparagraph 1 or 1.1 of paragraph 3 of Article 284 of the Tax Code of the Russian Federation.

The new special list includes 40 states and territories, which is significantly less than the list approved by Order No. 86n of the Ministry of Finance of the Russian Federation dated 05.06.2023.

Order No. 35n entered into force on the day of its official publication and applies to legal relations arising from January 1, 2024.

Document: Order of the Ministry of Finance of Russia from 28.03.2024 N 35n.

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