Consolidated Group of Taxpayers as a Holding-like Institution

Abstract

The article is devoted to the development of legal regulation of holdings in Russia taking into account changes entered into force to the Tax Code. The Tax Code introduces the notion of a consolidated group of taxpayers and refines the notion of interdependent parties; and both of these are close to the notion of holding from an economic point of view, however the notion of a consolidated group of taxpayers is more special, and the notion of interdependent parties is wider than the notion of a holding. Special tax control with antioffshore orientation is established for interactions of holding-like groups of companies. At the same time, measures motivating holding-like companies to be legally registered are imposed.

Keywords:

holding, taxation, consolidated group of taxpayers, interdependent parties, transfer pricing, profit tax, offshore tax haven, anti-offshore regulation