Redomiciliation of Foreign Companies in the Russian Federation: Assessment of the Aggregate Financial Result

Редомицилирование иностранных компаний в Российской Федерации: оценка совокупного финансового результата
A. S. Konduktorov
2021-03-18

Russian special administrative regionscash repatriationcompany redomiciliationdouble taxation agreementsreinvestment strategy
The paper attempts to assess the fiscal, investment, and monetary repatriation results of the application of legislation on the redomicilation of organizations registered in offshore states to Russian special administrative regions. The study was conducted in the context of the fundamental adjustment of agreements on the avoidance of double taxation concluded with foreign countries, which began in the summer of 2020 on behalf of the President of the Russian Federation. In this regard, the results obtained are more promising than current. In the course of the study, comparative legal and statistical methods were used, and the "reinvestment strategy" of economic entities, which is expressed in the reverse investment of funds previously transferred to the accounts of offshore organizations, was analyzed (In the context of changes in double taxation agreements). The outcomes of the analysis show that direct taxation of an international company that is redomiciled in the Russian Federation does not give a tangible fiscal result and is nothing more than a tool to increase the attractiveness of the Russian legal jurisdiction. However, the volume of mandatory investments accompanying the redomicilation procedure is significant in terms of the degree of financial burden on international companies, which should provide a fiscal effect for the budget system in the medium and long term. Cash-repatriation result of redomiciliation will be equal to the amounts reinvested in Russia from offshore countries; it is expressed in the improvement of the financial system of the Russian Federation by means of displacement of offshore practices. The author summarizes that, in general, the analysis of legal regulation indicates that the Russian Federation does not set the goal of increasing current budget revenues because of the application of the procedure of redomicilation of foreign organizations, but expects a promising financial and economic effect.
1
Direct taxation of redomiciled international companies produces no tangible immediate fiscal result and primarily enhances the attractiveness of Russian jurisdiction.
2
Mandatory investments required for redomiciliation impose a significant financial burden and are expected to generate budgetary effects over the medium and long term.
3
Russian redomiciliation policy prioritizes prospective financial and economic benefits rather than increasing current budget revenues.
4
The cash-repatriation effect equals funds reinvested in Russia from offshore jurisdictions, potentially strengthening Russia’s financial system by displacing offshore practices.
5
The study evaluates fiscal, investment, and monetary-repatriation effects of relocating offshore companies to Russian special administrative regions.

Redomiciled foreign companies in Russian special administrative regions

The aggregate fiscal, investment, and monetary-repatriation effects of company redomiciliation, including mandatory investments and reinvestment of offshore funds in Russia

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2021-03-18
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A. S. Konduktorov
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