Rules on taxation of profits of controlled foreign companies imposing a duty on legal entities who are Russian tax residents to assess, report and pay taxes on undistributed profits of foreign legal entities and foreign unincorporated structures, where they own, directly or indirectly more than 25% of the charter capital; or more than 10% of the charter capital if Russian persons in total own more than 50%, or which they otherwise control, subject to certain exemptions and temporary rules.