3 s. 11 s. 1 art. 251 of the Russian Federation Tax Code, a foreign organization of the transfer is completed with the provision that the income specified in this sub paragraph is determined by the tax base for income tax. The location of the transferring organization is not included in the list states and regions of the Russian Federation Ministry of Finance. 1 second. 3 arts. 284 of the Russian Federation Tax Code.
According to paragraphs. 1 second. 3 arts. The Russian Federation of the Tax Code approved the list of the States and regions that represent a preferential tax regime of the Russian Ministry of the Ministry of the Ministry of Russia and provides a preferential tax regime for taxation and providing information when financial transactions are made (on sea zones).
Please note that according to the 3rd of art. 3 of the federal law dated by the federal law dated 20.04.2014 3 N 81-F1 January 2015, 3 differences in the taxpayer before the taxpayer are taken into account in order to tax the institution earnings as determined before the date of the determined law. For this reason, the new accounting rules apply to the amounts that occur in relation to the transactions carried out as of 1 January 2015.
The total difference of the transactions before 01.01.2015 in the accounting for sorestinal tax was clarified after 01.01.2015. In the letter of the Russian Federation Ministry of Finance, the Russian Federation is not determined to use the term “transaction” for the N 03-03-06 / 1 / 17387Vergi of the Tax Code of the Russian Federation.
Corporate, concepts and other branches of the Russian Federation legislation used in the law of the Russian Federation of Article 11 of Article 11 of the Tax Act of the Tax Law is applied in the same sense. Used in these legislation branches, unless otherwise stated by the code.
Considering the above, in the sense that the Russian Federation is administered by the Tax Code, the Russian Federation is administered by the civil legislation of the Russian Federation and the legal entities that the procedures are considered as the actions of citizens and to establish civil rights and obligations (153 of the Russian Federation of the Federation of the Russian Federation). . Substance).
For this reason, for the transactions performed prior to January 1, 2015 after 1 January 2015, the organization must account for the income (expenses) of the organization (expenses) as of January 1, 2015. difference.
If the operations were made after 1 January 2015, the differences due to the re-valuation of damage and liabilities (from the devaluation) must be recognized as the exchange rate difference. At the same time, the Russian Federation announced that the Ministry of Finance should be paid and the receivable accounts should be redirected according to their date of origin.
Russia Ministry of Finance May 14, 2015 N 03-03-10 / 27647, N 81-FZ dated 20 April 2014 “second part of the Russian Federation Tax Code”
Russian Federal Tax Service was sent to NGD-4-3 / 11191, information and job with the letter of June 26, 2015.
N GD-4-3 / 6060 @ 20 in connection with the post dated 09.04.2015.