Annotation

In the current geopolitical environment, the Russian Federation has been subject to large-scale sanctions, which have directly impacted the legal regulation of controlled foreign companies (CFCs). In response to foreign economic challenges, Russian legislation has undergone significant changes aimed at mitigating the effects of sanctions and adapting the tax system for individuals and legal entities controlling foreign entities. This article examines the corrective measures approved in the Russian Federation in 2022 to support taxpayers managing foreign companies. It is concluded that the essence of the amendments is to encourage voluntary disclosure of information and simplify the calculation of the tax base. At the same time, regulatory changes have increased the level of legal and financial liability, requiring taxpayers to pay special attention to structuring their ownership of foreign assets. A comparative analysis of the legal regulation of liability for violating CFC rules in the Russian Federation and the Republic of Kazakhstan revealed comparable grounds and measures of liability, aimed at protecting the fiscal sovereignty of each state. At the same time, the CFC rules of the Republic of Kazakhstan are narrowly anti-evasion, while the updated Russian model has a distinctly anti-offshore focus.