Date of receipt of income in the form of profit from a controlled foreign company
The date of receipt of income in the form of profit from a controlled foreign company is recognized as December 31 of the calendar year following the tax period during which the date of the end of the period for which, in accordance with the personal law of such company, financial statements are prepared for the fiscal year falls. In the case where, according to the personal law of such company, there is no obligation to prepare and submit financial statements, this date is recognized as December 31 of the calendar year following the tax period during which the date of the end of the calendar year for which its profit is determined1.
Tax Code of the Russian Federation, as amended on May 21, 2020, Article 271, paragraph 12 // Official Gazette of the Russian Federation. 2000. No. 32. Item 3340. ↩