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5.10. Using Fiscal and Other Regulatory Tools to Expand the Tax Sovereignty of Russia: New Rules of the Game

May 19
Hall #5

Track:5. Investments / Finance


In recent years, Russian tax law has undergone many changes. Reforms still continue, now under the influence of a number of new factors. Adherence to the principle of freedom of capital flow in order to ensure its growth and a positive impact on economic development has led to this capital being transferred outside the Russian tax sovereignty due to insufficient systemic regulation.

This necessitates the legislator to carry out a number of fundamental reforms that need to be properly balanced.

On the one hand, there is a need for comprehensive regulation, which after many years of shadow economy would allow capital to move freely and be in the open market. Moreover, there is a need of fundamentally new fiscal instruments for the taxation of net income brought in by the “free” capital, even if this capital, inherently Russian, works outside of its borders.

On the other hand, however, lack of management experience in this field motivates to preserve relatively strict mechanisms of capital flow regulation, including the active use of such atavisms as restrictions stipulated by the Russian norms of monetary regulation.

It is safe to say that the main fiscal and regulatory measures controlling capital flow, as well as necessary taxation rules are currently in place. For instance, over the past two and a half years, new rules for taxation of income of controlled foreign corporations have been introduced; attempts to amnesty Russian capital have been made; currency control rules have been significantly adjusted.

These factors set out new rules of the game for all market players and define new limits of capital flow.

“Where are the limits of capital flow under the new regulatory framework?” – this is the main question participants of the round table are invited to discuss.

Panellists, taxation experts from major Russian and international companies who serve as experts in the legislative process, are invited to discuss the following issues:

  • Final version of CFC taxation rules and practical difficulties of their application by market participants;
  • Prospects of changing currency legislation, CFC rules, currency regulation and control legislation, as well as prospects of adoption of new legislative measures (such as changing individual tax residents regulation) aimed at expanding the Russian tax sovereignty;
  • Practical results of amnesty of capital programme; prospects, expectations and effects of “forced disclosure” due to entering the era of tax data transparency.


Dmitriy Mikhaylov

Partner, Ivanyan & Partners


Marina Belyakova

Parnter, EY

Daniil Egorov

Deputy Head, Federal Tax Service of the Russian Federation


Deputy Commissioner of Federal Tax Service of the Russian Federation

Сlass 2 Active State Advisor of the Russian Federation

Daniil Egorov was born in 1975 in Moscow.

1998: graduated from Peoples’ Friendship University of Russia with specialization in Legal Studies.

2000–2001: commission member of the Inter-Regional Bar for Entrepreneurs and Citizens Assistance.

2001: legal advisor, legal manager of ZAO Eneco.

2001–2003: 1st category specialist, consultant of Executive Support Department, Moscow Directorate, Ministry of Taxes and Assessments.

2003–2005: head of Information Support, Electronic Data Input and Desk Audit Department, then head of Desk Audit Department, Moscow Inter-District Inspectorate No 44, Ministry of Taxes and Assessments.

2005–2009: head of Desk Audit Department and Field Audit Department No 2, Moscow Inter-District Inspectorate No 50, Federal Tax Service.

2009–2010: deputy head of Examination Department, Moscow Directorate, Federal Tax Service.

2010–May 2011: deputy head of Private Litigation Examination Department, Largest Taxpayer Litigation Examination Department, deputy head of Directorate and head of Pre-Trial Audit Directorate, Federal Tax Service.

Coordinates and controls the following activities:

  • Control Directorate
  • Transfer Pricing Directorate
  • Desk Audit Directorate
  • Operative Control Directorate

Mr Egorov supervises the following areas:

  • Organization of enforcement control and monitoring of Russian tax and assessment laws and regulations; tax and assessments calculation control following the tax checks.
  • Methodological coordination of examination, monitoring, integration and analysis of tax check results.
  • Coordination of analysis and systematization of the means of tax evasion identified following the tax checks.
  • Ensuring cooperation of tax authorities with law enforcement and other governing bodies in identification, prevention and suppression of tax offences.
  • Coordination of the work of tax authorities on till equipment registration, organization and methodological support of monitoring of compliance by organizations and individual entrepreneurs with legal requirements on the use of till equipment in cash and/or plastic card transactions and on fullness of respective cash proceedings.
  • Coordination of the work of tax authorities in control and monitoring of national private and promotional lotteries, as well as the intended use of lottery proceeds.
  • Coordination of national lottery permitting.
  • Coordination of the issue of marking labels for tobacco and tobacco products made in Russia.
  • Coordination of licensing of fraud-resistant printing products, including securities blanks, and trade of such products; reissue of the documents confirming the licenses; suspension, revalidation and cancellation of licenses.
  • Coordination of gambling licensing of betting shops and betting terminals; reissue of the documents confirming the licenses; cancellation of licenses.
  • Coordination of technical verification of gambling equipment.
  • Coordination of tax control during tax checks of major taxpayers.
  • Coordination of foreign currency transactions by residents and non-residents, other than lending institutions or forex exchanges.
  • Organization of enforcement control and monitoring of Russian tax and assessment laws and regulations, as well as regulatory acts adopted following the tax checks, including regarding income tax returns.
  • Interaction with authorities, institutions, organizations and public officials regarding the provision of data to tax authorities from:
  • Pension Fund of the Russian Federation;
  • Social Insurance Fund of the Russian Federation.
  • Coordination of methodological and organizational support of Federal Tax Service and local tax authorities regarding tax administration of prices and transfer pricing for the purposes of taxation and tax risk identification.
  • Coordination of the work of Federal Tax Service and local tax authorities regarding the analysis and evaluation of market processes and pricing on external and internal Russian markets of goods (operations, services), mechanisms and tax consequences of transfer pricing for the purposes of taxation and tax risk identification.
  • Coordination of development of recommendations regarding tax legislation improvement, as well as improvement and automation of the forms and methods to ensure that deal prices correspond to market prices (economic feasibility).
  • Coordination and control of the work of Control Directorate, Desk Audit Directorate and Transfer Pricing Directorate.
  • Coordination of the work of Inter-District Desk Audit Inspectorate of the Federal Tax Service, Inter-District Major Taxpayer Inspectorate of the Federal Tax Service Nos 3 and 9.
  • Coordination of the work of Inter-District Taxation Pricing Inspectorate of the Federal Tax Service.
  • Coordination of the work of local tax authorities in Southern Federal Okrug, organization of its cooperation with the office of the plenipotentiary representative of the president of the Russian Federation in Southern Federal Okrug and with local authorities in Southern Federal Okrug.

Dmitry Zapol

International Tax Advisor, IFS Consultants

Mikhail Kazantsev

Business-Ombudsman for Deoffshorization and Capital Amnesty under the Presidential Commissioner for Entrepreneurs’ Rights

Ekaterina Lazorina

Partner - Russia and CIS Tax and Legal Leader, PwC

Mark Rovinskiy

Counsel, Ivanyan & Partners

*This schedule may be subject to change