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Capital Amnesty 4.0
Capital Amnesty 4.0
Protect your interests by participating in the fourth stage of Capital Amnesty
In current geopolitical environment, foreign states freeze and seize foreign assets of Russian nationals
5 reasons to participate in the 4th stage of capital amnesty
- 1Minimize the risk of blockingCapital Amnesty 4.0 provides an opportunity to minimize the risk of blocking or loss of assets in the jurisdiction of foreign (unfriendly) states
- 2Security assuranceSpecial declaration mechanism provides substantial security assurance to the applicant: exemption from criminal liability, tax liability and liability for violation of foreign exchange laws of the Russian Federation (covers violations until the special declaration submission date)
In particular, the amnesty provides exemption from tax liability on all statements provided by the Tax Code of the Russian Federation. Exemption from criminal and administrative liability is also provided for a range of statements subject to severe sanctions: from complete seizure of assets to imprisonment for up to six years - 3Tax exemption for declared assets, excluding income tax for CFC profit
- 4The 4th stage of capital amnesty provides an opportunity to the Russian holdings to restructure the group of companies without payment of transaction tax
- 5Participation in previous capital amnesty stages does not deprive of the right to participate in Capital Amnesty 4.0
WHO CAN PARTICIPATE IN CAPITAL AMNESTY 4.0
Only individuals can participate in capital amnesty: current or former tax and foreign exchange residents of Russia
Which assets can be declared in scope of Capital Amnesty 4.0
1
Controlled foreign companies (CFC)
2
Property
Land plots and other real estate assets, vehicles
3
Accounts with the banks opened outside Russia in favour of the applicant
4
Accounts with the banks, for which the applicant is the beneficial owner
5
Available cash
Government guarantees to the applicant
01
Protection of the applicant’s information
Information specified in the special declaration cannot be used by court instances under a criminal case, administrative or tax case.
02
Exemption from tax liabilities
The applicant or a person indicated in the special declaration cannot be subject to collection of tax in case of failure to pay or incomplete payment of tax as a result of:
a) transfer of property by nominee owner to actual owner;
b) purchase, use (establishment of acquisition sources) or disposal of: property, CFC, cash, opening, crediting of funds to accounts (deposits).
Tax is not collected if the liability for payment of relevant tax arisen with the applicant or other person before 1 January 2022.
a) transfer of property by nominee owner to actual owner;
b) purchase, use (establishment of acquisition sources) or disposal of: property, CFC, cash, opening, crediting of funds to accounts (deposits).
Tax is not collected if the liability for payment of relevant tax arisen with the applicant or other person before 1 January 2022.
03
Exemption from liability for failure to submit documents certifying financial performance of the CFC for financial years that ended in 2020–2021
04
Exemption from income tax on income in form of property / title obtained in 2022 by individuals from their CFC
Specific features and difference from previous stages
1
The main difference of the new fourth stage is the possibility to legalize cash and other financial assets
Securities, financial derivatives, receivables on insurance contracts, etc
2
The main condition for amnesty of these assets is their transition or crediting to accounts with Russian banks
3
The special declaration in scope of Capital Amnesty 4.0 can be submitted only once. Specified declaration is not accepted
How lawyers of INTANA Legal can help you in scope of Capital Amnesty 4.0?
- We consult on all issues associated with the new amnesty stage1
- We develop optimal solutions to participation in capital amnesty2
- We prepare necessary documents on administered assets3
- We provide support throughout the entire declaration process with the Russian tax authorities4
- We provide comprehensive legal support to CFC in Russia.As well as redomiciliation services for CFC from unfriendly states into friendly states, as well as for CFC liquidation.5
Head of Tax Practice
Head of Tax Practice
Dmitrii Barskii
Legal practice: 15 years
Dmitrii possesses large experience in consulting financial, agro-industrial and production companies.
For 15 years, Dmitrii consults and represents clients during tax audits, successfully protects the interests of taxpayers in administrative proceedings and in court, manages tax Due Diligence, and supports business restructuring projects.
See portfolio →
For 15 years, Dmitrii consults and represents clients during tax audits, successfully protects the interests of taxpayers in administrative proceedings and in court, manages tax Due Diligence, and supports business restructuring projects.
See portfolio →
- Dmitrii BarskiiLegal practice: 15 yearsDmitrii possesses large experience in consulting financial, agro-industrial and production companies.
For 15 years, Dmitrii consults and represents clients during tax audits, successfully protects the interests of taxpayers in administrative proceedings and in court, manages tax Due Diligence, and supports business restructuring projects.
See portfolio →
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