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Globe-Trotting
Sportsman Or Entertainer: Russia
A
Russian citizen with extensive, international,
multi-sourced income is not in a good
tax situation unless he or she can establish
non-residence, since full, world-wide
taxation of income and capital gains will
apply.
Russia has tax treaties with about 75 other countries, but if resident
in Russia, the peripatetic professional may well find himself paying
withholding tax in a number of countries which cannot in some cases
be reclaimed or set off against Russian taxation because of the
absence of a tax treaty.
Such
an individual will almost certainly resort
to corporate structures to market his
or her skills and manage derivative income
flows. It may well be that these can usefully
be based in offshore jurisdictions, although
complex structures may be necessary if
corporate anti-avoidance rules are to
be avoided. The Canary
Islands also offer some possibilities.
Due
to new rules which exempt incoming dividends
from taxation, Russia has become a relatively
attractive location for a holding company
for overseas assets.
Apart
from the extra difficulty of minimising
tax on the income side, a Russian-resident
sportsman or entertainer will be in the
same position as any other Russian resident.
(Select 'High-Tax Country Resident' and
'Russia' for a fuller description).
If
a foreign sportsman or entertainer becomes
a Russian resident, then he or she is
in the same position as an expatriate
executive (select 'Expatriate Executive'
and 'Russia').
www.lowtax.net
contains details of the offshore business
sectors of 50 jurisdictions, and their
taxation.
NB: The suggestions given above do not
constitute investment advice. They are intended
only to assist individuals in finding appropriate
professional advice, which is essential
for anyone planning offshore investment.
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