2015 kpmg ema tax summit€¦ · retail market rub 60.7 trln rub 45.5 trln rub 30.1 trln by 8%...
TRANSCRIPT
Russia’s Changing Economic Environment
Bob WallingfordPartner, Tax and Legal ServicesTax Head of Japan Global Tax Practice KPMG in Russia and CIS
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Macroeconomic overview of the Russian Federation 2015
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Macroeconomic overview of the Russian Federation 2015
to 75%
Share of walletfor goods and servicesby
4%
GDP
by 11.3%
Real disposable income in 2012 terms
to 8,3% (Aug 7.8%)
Unemployment
to 23.7%
Food Inflation
RUB 60.3 trln
RUB 18 trln
by 12%
Retail market
RUB 60.7 trln
RUB 45.5 trln
RUB 30.1 trln
by 8%
Household consumption
Sources: Federal State Statistics Bureau, EIU, Bloomberg, Investment banks reports, Ministry of Economic Development, KPMG analysis, pries base period 2012
Takeaway Political an economical issues 2014-2015 drove Russian economy to the recession. What are the perspectives?
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Russian GDP forecast
* All following GDP forecasts are given in the prices of base period (2012) unless otherwise specified
Forecast
GDP forecastRUB trln*
Sources: EIU, Bloomberg, KPMG analysis
After the economy shock in 2014/15, Russia is expected to be back to 2014 year level in 2018, following the slow rate recovery starting 2016
63,2
2017
64,2
20202015 2018
65,1
61,9
60,7
63,2
2016 20192014
61,0
- 4% GDP in 2015 (in comparison with 2014)
CAGR2015-2020: 1,4%
GDP RUR: Y2018 = Y2014
Comments
$
Forecast 2015:
61,1 RUR/USDAverage Jan – Jul 2015:
57,4 RUR/USD
Exchangerate
Takeaway
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GDP growth drivers
GDP growth drivers magnitude*, 2015-2020%, RUB trln
Sources: EIU, KPMG analysis
■ Steadily increasing household consumption forecasted to support GDP growth in 2015-2020■ Investments which are hit the most are also expected to recover
2.1
1.1
0.9
0.3
4.4
7.5%
InvestmentsHousehold consumption
23.9%
Total increase
Net export
100%
Government spending
21.4%
47.2%
$
1,4%
2%
1,4%
0,9%
CAGR, 2015-2020
Household consumption
Investments
Government spending
Net export
Comments
* All numbers are given in the prices of base period (2012)
Takeaway
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Global retail market attractiveness(a) Comments
Russian vs. Global consumer markets
(6)
(4)
(2)
0
2
4
6
8
10
12
14
16
18
3.5002.0001.000 2.5005000 4.0003.0001.500
YR
etai
l rev
enue
CAG
R,%
, 201
4-20
17
Germany
Russia’15 forecast
Retail sales forecast US$, 2015
Russia “14
US
Japan
Brazil
India
China
Currently Russian consumer market is less attractive to the investors than other BRIC markets
Average cost of capital
to 21st place 2015(from 12th in 2014)
Note: (a) Bubble size represents country’s population Source: Economic Intelligence Unit Forecast. 1Q2015; Bloomberg data; KPMG analysis, A.T. Kearney Global Retail Development Index™
Inflation to 13.9%
Р
%to 18.3%
Global Retail Development Index™
Takeaway
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Forecast
Total retail revenue in Russia by segments*RUB trln in the prices of base period (2012)
Comments, 2014-2017
Source: Economic Intelligence Unit forecast, July 2015, Canadean, KPMG analysis
Overall consumption structure will remain untouched due to an increased debt/income ratio of households
Retail market
Debt/income ratio
Home and garden products
by 10%
to 57%
8 %
D I
of sales
61%
10%
18,6
2016
10%
11%
2017
8%8%11%
18,6
10%
10%
61%
10%
9%
11%
10%
+1%-10%
19,0
2015
8%10%
61%
10%
11%
61%
2014
20,7
Apparel and accessoriesFood and grocery Home and garden products
Electrical and electronicsOthers (less than 1 trln RUB)
* All numbers are given in the prices of base period (2012)
Retail Revenue
Takeaway
Russia’s Changing Tax Environment
Evgenia WolfusPartner, International TaxHead of Indirect Tax and Transportation SectorKPMG in Russia
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Part of “deoffshorisation” package – Amnesty Law to allow individuals to legalise property located outside Russia
Russian tax concerns – ‘Deoffshorisation’
Russian tax residents were legally able to send funds offshore and then to continue to earn income on those funds, in each case without paying any Russian tax
Deoffshorisation combats tax base erosion and the use of offshore companies by Russian businesses
There are three key goals for Deoffshorisation:
Prevent funds from being sent offshore without tax by:
■ Limiting the use of DTTs through the ‘Beneficial Owner’ concept.
Tax funds which are offshore by:
■ Broadening the Tax Residency rules for companies
■ Enacting Controlled Foreign Company (‘CFC’) rules
Force Russian tax residents to return funds to Russia by:
■ Taxing CFC passive income at the normal corporate income tax rate (20%), rather than at the lower tax rate for dividends (0% or 13%) (‘active’ companies are not CFCs)
■ Requiring the payment of dividends back to Russia to avoid the CFC tax
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‒Executive function is performed on a regular basis from Russia or‒Steering management is performed predominantly in Russia by
the top managers of the company
‒Financial accounting or management accounts and records are maintained in Russia‒Company`s documents are generated and processed in Russia‒Day-to-day human resource management is performed in Russia
Tax residency – General provisions
Principal criteria:
Tie-breaker rules:
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Tax residency – Implications
■ Russian CIT (20%) is imposed on HoldCo’s profits (or 0%/13% for dividends)■ Recalculation of HoldCo’s profits according to Chapter 25 of the Russian Tax Code■ Russian Withholding Tax (WHT) is imposed on the distribution of profits by HoldCo to
Investors (the tax rates of Russian DTTs are applied if the conditions are met)
Foreign HoldCo’s profit is subject to Russian CIT
Investors
ForeignHoldCo
RusCo
HoldCo considered a Russian tax
resident
Distribution of profits
subject to Russian WHT!
For illustration purposes
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Drastic change from a form-based approach to the application of DTT prevalent in Russia before 2015.
Beneficial owner of income paid out of Russia for the purpose of application of DTTs concluded with Russia: ■ An entity who has the right to use income OR■ On whose behalf another entity has the authority to use income
!
NOT a beneficial owner if:■ Limited authority to dispose of income or mere functions of an intermediary with respect to such income.■ No additional functions or risks with respect to the income■ Onwards distribution of income to an entity that is not entitled to benefits under DTT concluded with Russia
‘Look through’ approach specifically set forth in the law if the immediate recipient of income is NOT a beneficial owner:■ Russian beneficial owner: WHT for dividend income at 0% (for companies with qualifying investment) or 13% (in
other cases)■ Foreign beneficial owner: WHT in accordance with DTT between its country and Russia
Beneficial ownership of income – Now explicitly defined in the Russian tax law
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Beneficial ownership of income - Example for typical active holding company
Key features of Active Co■ Sufficient level of substance.■ Retention and reinvestment of dividend income
by Active HoldCo.■ Appropriate experience and qualification of the
BoD.■ Confirmation that directors exercise discretion
over the income.
Structuring considerations■ Indirect participation by Active HoldCo equated
with direct participation by Foreign SubHoldCo BUT other conditions for reduced WHT rate also relevant (depending on the treaty).
■ Use of intermediary holding companies minimised.
ActiveHoldCo
ForeignSubHoldCo
RusCo (1) RusCo (2)
Russia
Foreign jurisdiction
Dividends
Dividends
Dividends
Beneficial owner
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Beneficial ownership of income – Look through approachExample for investor structure (in the event of low substance)
Waiver of rights of CyprusHoldCo under Russia-Cyprus DTT and declaration of investors as beneficial owners of dividend paid by RusCo■ WHT on distribution of dividends:
– 0% (Russian companies with qualifying investments), or 13% (other Russian investors).
– Rate under applicable DTT rate (for foreign investors).■ Ultimate savings in the amount of 5% WHT in Russia
relating to the part attributable to Russian investors.■ Potential need for a direct shareholding in the capital of
RusCo by a foreign investor wishing to apply a DTT with Russia.
But■ Tax risks for prior periods.■ Lack of clarity on how the Russian tax authorities will
check beneficial ownership or absence thereof.■ It is still unclear how low substance structures will be
affected by the OECD BEPS project.RusCo
CyprusHoldCo
OffshorePE Fund
Not a beneficial
owner
Nota beneficial
owner
Foreign Investor Russian Investor
Beneficial owners
Dividends
Dividends
DividendsWHTunder
DTT with investor’s country
0/13% WHT
Low substance
Low substance
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Beneficial ownership of income – Implications for typical financing structures
Possible structureCurrent structure
OffshoreCo
FinCo(DTT)
RusCo
Loan
Loan Interest
Interest
Reduction of tax base by interest payable to OffshoreCo
OffshoreCo
FinCo(DTT)
RusCo
LoanInterest
Reduction of tax base through other mechanisms (e.g. deemed interest deduction)
Transition to more sophisticated structures
Enhancement of substance of FinCo in a foreign jurisdiction
Capital contribution/non-interest-bearing loan
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Taxation of indirect sale of Russian real property
Commercial Real Estate Oil and Gas
Company 1 Company 2 Company 3
Foreign Investor’s Consortium –
Cyprus
Russian Oil&GCo
51% 49%
Foreign JV Co
Russian Group Foreign Group
Foreign parent SPV
Russian SPV
Foreign company with Russian
branch
Russian OpCo
Capital gains effectively exempt before 2015 but taxable from 2015
■ No effective mechanism for the payment of tax on foreign to foreign transaction.
■ A few treaties restricting Russian taxing rights (but renegotiation for some in process).
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Legislative trends
Additional attention to expenses deductibility and application of tax incentives
Deoffshorizationlaw
Transfer pricing rules
Thin capitalization rules
Tax incentives Special investment
contracts Partial restriction
of foreign-made products access to the public procurement system
Prevent funds from being sent offshore
Necessity to increase tax budget
Localization and import substitution
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Trends in the legislation application
1Active application of «substance over form» approach
2Critical approach to assessment of documents and
economic operations nature
3 Interdependence as a ground for additional scrutiny
4 Active application of all available sources of evidence
5Claims to operations, which are difficult for defense by
taxpayer
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Current risk areas of additional tax assessment
1
2Justification of tax incentives application
(e.g., Volkswagen, IKEA, PCM Motors, International paper)
3 PE risks (e.g., Astellas, Berlin-Chemie)
4 Unjustified tax benefit
■ Royalties ■ Interests■ Cost sharing
■ Imputed income
■ Federal and regional tax incentives
■ Additional attention to business structures when goods are sold directly by foreign entity
■ Application to continuing operations■ Blurring of lines between «interdependence» and «affiliation»
Additional attention to all payments outside Russia
(e.g., Oriflame, Suninbev, Ecvant, ADL production)
Russia’s Changing Tax Environment
Victoria SamsonovaDirector, Corporate TaxHead of Healthcare & PharmaceuticalsKPMG in Russia and CIS
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Investment climate in Russia – turbulent times
RUB depreciation, decrease of import
Increased “country risk”
Consumer demand shrinking
International sanctions tightening
Rapidly changing domestic legislationLocal production cost reduced
Decrease of competition level
Demand for less expensive commodities
State incentives for investors
Law-making opportunities
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Localization and import substitution as economic policy flagships
Russian Government is developing specific action plans for import substitution
The share of imported goods consumed by Russia to be gradually reduced by 2020 in more than 20 industries
Some types of foreign products to be restricted from access to state procurement
Measures to stimulate the manufacturing localization by multinationals are under active elaboration
Priority segments: Industrial Equipment, Hi-Tech Equipment, Chemicals & Petrochemicals, Pharmaceuticals, Medical Devices, Electronics
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Localization – ways of market entry
Distribution contract
Sales support office / Trading subsidiary in Russia
■ Direct sales of finished goods to Russia from abroad
■ A representative office / branch / subsidiary engaged in marketing and sales support
■ A Russian subsidiary importing and distributing finished goods in Russia
■ Contracting with a local partner possessing production facilities
Acquiring a local player
■ Including “ready-to-go” and “brownfield” options
Greenfield
■ Investment into construction of a local full-cycle manufacturing site
Contract manufacturing / Assembly
Priority
localization
forms
in terms of the state support
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Forms of investors support from the state
Locations for new manufacturing sites, providing land plots with the infrastructure, energy, utilities Subject to certification and expert assessment by a special body A special provider of facility management and support to residents on regulatory / administrative matters No special legal status; tax benefits may be available under regional laws
Industrial Parks and Technoparks
Reduced rates / exemptions for corporate profits tax, property tax, customs duties, social insurance contributions Applies to new construction as well as the existing facilities expanding/modernization An investment agreement to be signed with the regional authorities Could be obtained retro-actively; criteria (the minimal investment volume, payback term) differ per regions
Special legal status, tax and customs benefits Four types: Manufacturing; Technological (Innovation); Touristic (Recreational); Logistic (Port) Support with infrastructure, utilities, administrative work of obtaining residence
Special Economic Zones
Structured incorporation of integrated industrial, scientific, financing, infrastructural entities Operating with state support and aimed at development of a particular industry (group of industries) No special legal status; tax benefits may be available under regional laws
Industrial Clusters
Regional Tax Benefits
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Incentives for investors in Russia – examples
Special Economic Zone Industrial Cluster
Industrial Park Regional tax concession
Kaliningrad
PskovMoglino SEZ
St. PetersburgInnovation SEZPharma Cluster
KhabarovskAircraft & Shipbuilding
Innovations ClusterDalEnergoMash Park
VolgogradNikoKhim Park
IrkutskAngarsky Park
Moscow regionStupino Park
Innovation SEZ
KrasnoyarskKrasny Yar Park
Innovations Cluster
KalugaPharma ClusterLyudinovo SEZ
YaroslavlBiopharma ClusterAutomotive Cluster
TatarstanAlabuga SEZ
ChelyabinskStankomash Park
Altaysky regionBiopharma Cluster
BashkortostanPetrochemical Cluster
NovosibirskIT & Medical Cluster For illustration purposes
Russia’s Changing Tax Environment
Bob WallingfordPartner, Tax and Legal ServicesTax Head of Japan Global Tax Practice KPMG in Russia and CIS
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Foreign Company
Russian Sales Co• Some profits
Russian Manufacturing Co
• Only losses
Unrelated Shareholder
100%20%
For illustration purposes
Legal Entity SimplificationRevising Russian Holding Company Structures
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Foreign Company
Russian Co 1• Operations
Russ Co 2• Operations
Netherlands Company
• No Substance
RussianManagement Co
• Real Estate
Related Individual Shareholder
100% 100%80%20%
For illustration purposes
Legal Entity SimplificationRevising Foreign Holding Company Structures
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Co
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Acc
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ERP-system:
80% of Russian companies have documents workflow like this:
COSTLY SLOWLY MANY ERRORSNO CONTROL
Man
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dat
ain
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For illustration purposes
Efficiency/OptimizationPaper Documentation
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Co
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ERP-system
Au
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pro
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ing
of
imag
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Optimized documents workflow will be like this:
Accounting
FAST COST REDUCTIONMINIMUM OF
ERRORS CONTROL
Clie
nt’
s ac
cou
nti
ng
do
cum
ents
Inspection
XML
Electronic archive
Operators of electronic exchange
Analysis of processes
related to documents
workflow
Assistance in
preparation of
requirements for IT
solutions
Assistance in
selection of IT
solutions and
vendors
Quality control
during
implementation of
IT solutions
Development of
recommendations and
assistance in their
implementation
KPMG services
For illustration purposes
Efficiency/OptimizationPaper Documentation
35
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