Russia’s Controlled Foreign Company Rules – A Discussion of Effectiveness in Light of the OECD’s Recommendations

Abstract

This article assesses the effectiveness of Russia’s recently introduced controlled foreign company (‘CFC’) rules against the recommendations for the Design of Effective Controlled Foreign Company Rules as prescribed by the Organisation for Economic Co-operation and Development (‘OECD’). This article, through the lens of comparative analysis, endeavours to respond to the question of whether the Russian CFC rules are effective given their current construction. The article responds affirmatively to the research question and notes that the CFC rules are broadly effective given Russia’s political and economic directives although not beyond reproach.