Not an offshore company 44 fz declaration. Offshore companies - what is it? How to check if a company is offshore? What exactly do companies of this type offer?

Include in the Federal Law of April 5, 2013 N 44-FZ "On the contract system in the field of procurement of goods, works, services to meet state and municipal needs" (Sobranie Zakonodatelstva Rossiyskoy Federatsii, 2013, N 14, art. 1652; N 27, 3480; N 52, item 6961; 2014, N 23, item 2925; N 30, item 4225; N 48, item 6637; N 49, item 6925; 2015, N 1, item 11, 51, 72; N 10, article 1418; N 14, article 2022; Official Internet portal of legal information (www.pravo.gov.ru), June 30, 2015, N 00012015063000082; July 1, 2015, N 0001201507010036) the following changes:

1) Clause 4 of Article 3 after the words "origin of capital" shall be supplemented with the words ", with the exception of a legal entity whose place of registration is the state or territory included in the list of states and territories approved in accordance with subparagraph 1 of clause 3 of Article 284 of the Tax Code of the Russian Federation, providing a preferential tax regime for taxation and (or) not providing for the disclosure and provision of information when conducting financial transactions (offshore zones) in relation to legal entities (hereinafter referred to as an offshore company),";

2) in Article 14:

a) in Part 4, the words "a ban, restrictions have been established" shall be replaced by the words "a ban has been established";

b) add part 6 of the following content:

"6. Regulatory legal acts provided for by parts 3 and 4 of this article and establishing restrictions, conditions for the admission of goods originating from foreign states, works, services, respectively, performed, provided by foreign persons, for the purposes of procurement, cases may be determined in which the customer in the performance of a contract, they are not entitled to allow the replacement of goods or the country (countries) of origin of goods in accordance with Part 7 of Article 95 of this Federal Law.";

3) in Article 31:

a) Part 1 shall be supplemented with paragraph 10 of the following content:

"10) the procurement participant is not an offshore company.";

b) part 8 shall be stated in the following wording:

"8. The Procurement Commission shall verify the compliance of procurement participants with the requirements specified in paragraph 1, paragraph 10 (except for the cases of holding an electronic auction, request for quotations and preliminary selection) of Part 1 and Part 1.1 (if such a requirement exists) of this Article, and in in relation to certain types of procurement of goods, works, services, the requirements established in accordance with parts 2 and 2.1 of this article, if such requirements are established by the Government of the Russian Federation. 9 of part 1 of this article, as well as during an electronic auction, request for quotations and preliminary selection of the requirement specified in paragraph 10 of part 1 of this article. these requirements are established by the Government of the Russian Federation in accordance with Parts 2 and 2.1 of this Article.";

d) add part 8.2 with the following content:

"8.2. The customer checks the compliance of the participant in the request for quotations, with whom the contract is concluded, with the requirement specified in paragraph 10 of part 1 of this article, when concluding the contract.";

4) in part 15 of Article 34 the words "40 and 41" shall be replaced by the words "40, 41, 44 and 45";

(see text in previous edition)

6) Article 73 shall be supplemented with part 3.1 of the following content:

"3.1. A participant in the request for quotations who submitted an application for participation in the request for quotations is considered to have provided the customer with information on its compliance with the requirement specified in paragraph 10 of Part 1 of Article 31 of this Federal Law.";

7) Part 11 of Article 78 after the words "signed contract" shall be supplemented with the words "and an extract from the unified state register of legal entities or a notarized copy of such an extract (for a legal entity), which were received no earlier than six months before the date of placement in the unified information system for notification of a request for quotations, a duly certified translation into Russian of documents on state registration of a legal entity in accordance with the legislation of the relevant state (for a foreign person)";

8) Article 80 shall be supplemented with part 5.1 of the following content:

"5.1. A participant in the preliminary selection who has submitted an application for participation in the preliminary selection is considered to have provided the customer with information on its compliance with the requirement specified in clause 10 of part 1 of Article 31 of this Federal Law.";

9) in Article 93:

a) in part 1:

Supplement paragraph 44 with the following content:

"44) the purchase by state and municipal libraries, organizations engaged in educational activities, state and municipal scientific organizations of services for granting the right to access information contained in documentary, documentographic, abstract, full-text foreign databases and specialized databases of international scientific citation indices from operators of said databases included in the list approved by the Government of the Russian Federation;";

Supplement paragraph 45 with the following content:

"45) the purchase by state and municipal libraries, organizations engaged in educational activities, state and municipal scientific organizations of services for granting the right to access information contained in documentary, documentographic, abstract, full-text foreign databases and specialized databases of international scientific citation indices from national libraries and federal libraries with a scientific specialization, and the price of such a contract concluded with a single supplier (contractor, performer) is determined in accordance with the procedure established by the Government of the Russian Federation.";

In Russia, an unequal battle with offshore companies continues. How successful this battle is, we will not find out now. We are more interested in how it affects the public procurement system.

The law on the contract system, as amended by Federal Law No. 227-FZ of July 13, 2015, received a very interesting new rule regarding the admission of offshore companies to participate in the Russian state order. (An overview of the editions of 44-FZ can be found.

As you know, until recently, the concept of a procurement participant was as broad as possible, allowing, in the general case, individuals and legal entities from all over the world to come to the market of the Russian state order. Yes, in fact, a “foreigner” could not participate in electronic procurement due to problems with obtaining an electronic signature, but de jure access to public procurement was open to representatives of all countries.

A new edition of paragraph 4 of Art. 3 44-FZ, which excluded legal entities registered in offshore jurisdictions from the procurement participants. New provisions of the article are highlighted:

4) procurement participant - any legal entity, regardless of its organizational and legal form, form of ownership, location and place of origin of capital, with the exception of a legal entity whose place of registration is the state or territory included in the approved in accordance with subparagraph 1 of paragraph 3 of the article 284 of the Tax Code of the Russian Federation, a list of states and territories that provide a preferential tax regime for taxation and (or) do not provide for the disclosure and provision of information when conducting financial transactions (offshore zones) in relation to legal entities (hereinafter referred to as an offshore company), or any individual, in including registered as an individual entrepreneur;

Part 1 Art. 31 was supplemented by a concise paragraph 10:

10) the procurement participant is not an offshore company.

Interestingly, the prohibitive norms were framed not only as a requirement for participants, but also as an exception to the very concept of “participant”. Are you from the Cayman Islands? You are no longer a procurement participant at all! Such a construction of norms, in my opinion, is redundant: a participant cannot be an offshore company, and an offshore company cannot be a participant.

Mechanisms were introduced to implement measures to block the participation of offshore companies in procurement. The mechanisms turned out to be different depending on the methods of determining suppliers (contractors, performers).

Open competition, limited participation competition, two-stage competition.

Procurement participant.

Customer commission.

It is obliged to check that the participant is not an offshore company (see part 8 of article 31 44-FZ in the new edition):

The Procurement Commission shall verify the compliance of procurement participants with the requirements specified in paragraph 1, paragraph 10 (except for the cases of an electronic auction, request for quotations and preliminary selection) of part 1 and part 1.1 (if such a requirement exists) of this article, and in relation to certain types procurement of goods, works, services to the requirements established in accordance with parts 2 and 2.1 of this article, if such requirements are established by the Government of the Russian Federation.

Customer.

Electronic auction.

Procurement participant.

Neither by submitting an application, nor ever again, does he declare or confirm in any way that he is not an offshore company.

Customer commission.

Has the right to check that the participant is not an offshore company (see part 8 of article 31 44-FZ in a new edition):

The procurement commission has the right to check the compliance of procurement participants with the requirements specified in clauses 3-5, 7-9 of part 1 of this article, as well as during an electronic auction, request for quotations and preliminary selection with the requirement specified in clause 10 of part 1 of this article. The Procurement Commission is not entitled to impose on the procurement participants the obligation to confirm compliance with the specified requirements, except for the cases when the specified requirements are established by the Government of the Russian Federation in accordance with Parts 2 and 2.1 of this Article.

Customer.

The right, as before, to check and establish that the participant does not meet the requirement or provided false information about compliance. Consequences - see part 15 of Art. 95 of the law.

Site operator.

The Operator is entrusted with a new function to check the participant's compliance with the requirements. Previously, the Operator, by virtue of the law on the Constitutional Court, did not check compliance with any requirements. Article 31 of the 44-FZ was supplemented by part 8.1:

8.1. The operator of the electronic site shall check the compliance of the participant of the electronic auction with the requirement specified in clause 10 of paragraph 1 of this Article, when accredited on the electronic site.

At the same time, the list of grounds for refusal of accreditation has been expanded:

The operator of an electronic site is obliged to refuse accreditation to an electronic auction participant if they fail to provide the documents and information specified in Part 2 of this Article, or if they provide documents that do not meet the requirements established by the legislation of the Russian Federation, and also if such participant is an offshore company.

All participants already accredited to the EP, which are offshore companies, should have had their accreditation terminated. This is also a function of the ES operator (see Part 2 of Article 2227-FZ):

From the date of entry into force of this Federal Law, the operator of the electronic site shall terminate the accreditation on the electronic site of a procurement participant that does not meet the requirement specified in paragraph 10 of Part 1 of Article 31 of the Federal Law of April 5, 2013 N 44-FZ "On the contract system in the field of procurement goods, works, services to meet state and municipal needs" (as amended by this Federal Law). At the same time, the blocking of funds contributed by such a participant as security for an application for participation in an electronic auction is terminated.

Quote request.

Procurement participant.

When submitting an application, he does not separately declare and does not confirm in any way that he is not an offshore company. Moreover, the very fact of filing applications is recognized as a declaration (see Part 3.1. Article 73 44-FZ):

3.1. A participant in the request for quotations who submitted an application for participation in the request for quotations is considered to have provided the customer with information on its compliance with the requirement specified in paragraph 10 of Part 1 of Article 31 of this Federal Law.

However, the procurement participant is obliged to confirm compliance with the requirement when concluding the contract. Article 79 is supplemented by part 11:

In the event that the winner of the request for quotations did not provide the customer with a signed contract and an extract from the unified state register of legal entities or a notarized copy of such an extract (for a legal entity), which were received no earlier than six months before the date of placement in the unified information system of the notice on the request for quotations, a duly certified translation into Russian of documents on the state registration of a legal entity in accordance with the legislation of the relevant state (for a foreign person) within the time period specified in the notice of the request for quotations, such a winner is recognized as evading the conclusion of the contract.

Thus, when conducting a request for quotations, it is most difficult to confirm that you are not an offshore organization. It is worth paying attention to the fact that it is not directly named in what form the extract or its copy is provided. Formally, the extract is no longer related to the application, therefore it can be submitted in any form, including electronic. Also, it is not at all necessary to submit an extract and a signed contract at the same time. It is important that this is done within the allotted time.

Customer commission.

Has the right to check that the participant is not an offshore company (see part 8 of article 31 44-FZ in a new edition).

Customer.

It is obliged to recognize the participant as having evaded the conclusion of the contract in case of failure to provide an extract.

The right, as before, to check and establish that the participant does not meet the requirement or provided false information about compliance. Consequences - see part 15 of Art. 95 of the law.

Request for proposals.

Procurement participant.

Since the requirements for the composition of the application are still not directly regulated by law, the customer has the right to establish certain requirements for documents, information confirming compliance with the requirement.

Customer commission.

Customer.

The right, as before, to check and establish that the participant does not meet the requirement or provided false information about compliance. Consequences - see part 15 of Art. 95 of the law.

Preliminary selection.

Procurement participant.

When submitting an application, he does not separately declare and does not confirm in any way that he is not an offshore company. Moreover, the very fact of filing applications is recognized as a declaration (see Part 5.1. Article 80 44-FZ):

5.1. A participant in the preliminary selection who has submitted an application for participation in the preliminary selection is considered to have provided the customer with information on its compliance with the requirement specified in paragraph 10 of Part 1 of Article 31 of this Federal Law.

When concluding a contract, rules similar to a simple request for quotations apply. Thus, an offshore company may be among the participants in the preliminary selection, pass it and get into the list of suppliers.

Customer.

Similar to a regular request for quotes.

Closed competitions.

Similar to open competition.

Closed auction.

Procurement participant.

No innovations were introduced. The participant still submits a copy of the extract from the Unified State Register of Legal Entities as part of the application (see subparagraph b), paragraph 1, part 2, art. 88 of the law).

Customer commission.

It is obliged to check that the participant is not an offshore company (see part 8 of article 31 44-FZ in the new edition).

Now a few questions regarding the application of the new rules.

What are these offshore companies?

By virtue of the tax legislation of Russia, offshore zones are states and territories that provide a preferential tax regime for taxation and (or) do not provide for the disclosure and provision of information when conducting financial transactions.

Such zones, by virtue of the order of the Ministry of Finance of Russia dated November 13, 2007 No. 108n, include:

Anguilla;
Principality of Andorra;
Antigua and Barbuda;
Aruba;
Commonwealth of the Bahamas;
Kingdom of Bahrain;
Belize;
Bermuda;
Brunei Darussalam;
Republic of Vanuatu;
British Virgin Islands;
Gibraltar;
Grenada;
Commonwealth of Dominica;
People's Republic of China: Hong Kong Special Administrative Region (Hong Kong);
Macau Special Administrative Region (Maomen);
Union of the Comoros: Anjouan Island;
Republic of Liberia;
Principality of Liechtenstein;
Republic of Mauritius;
Malaysia: Labuan Island;
Republic of Maldives;
Republic of the Marshall Islands;
Principality of Monaco;
Montserrat;
Republic of Nauru;
Curaçao and Saint Martin (Dutch part);
Republic of Niue;
United Arab Emirates;
Cayman Islands;
Cook Islands;
Turks and Caicos Islands;
Republic of Palau;
Republic of Panama;
Republic of Samoa;
Republic of San Marino;
Saint Vincent and the Grenadines;
Saint Kitts and Nevis;
Saint Lucia;
Separate administrative divisions of the United Kingdom of Great Britain and Northern Ireland: Isle of Man;
Channel Islands (Guernsey, Jersey, Sark, Alderney);
Republic of Seychelles.

Will a company registered in the Russian Federation (or another country that is not related to offshore zones) the founder (participant, shareholder) of which is an offshore company be a participant in the procurement?

Yes, it will. There are still no restrictions on the place of origin of capital. That is, an offshore company, “expelled” from the Russian state order, will be able to become the founder of a Russian company, and this “daughter”, in turn, will be able to take part in procurement on a common basis.

Can an individual who is a citizen of a state, an offshore zone, be a procurement participant?

Yes, as restrictions are imposed only on legal entities. So we are waiting for an influx of applications from the citizens of San Marino and Mauritius)).

And what about representative offices of offshore companies?

But for them, the entrance is closed: the representative office, by virtue of the Civil Code of the Russian Federation, is not a legal entity and acts on behalf of a legal entity. So the ban will work.

How can the commission or the customer check if the participant is an offshore company?

Having information about the location of the participant, it is quite simple to do this - just study the above Order of the Ministry of Finance of the Russian Federation. Also, interested parties can send a request to the Tax Service, which maintains the State Register of accredited branches, representative offices of foreign legal entities (see Order of the Federal Tax Service of Russia dated December 26, 2014 No. ММВ-7-14/683@).

How to deal with contracts already concluded with offshore companies?

They will retain their force and will be performed in the general order.

Now let's look at the official website in the register of contracts, whether there are any contracts concluded earlier with offshore companies. 81 entries were found throughout the list of countries, but all of them are inaccuracies of the site. Disappointment. Where are the billions that flowed to the Cook Island?

Business is a complicated thing. And cruel. In the world of money, transactions and business suits, there are hundreds of traps that threaten the entrepreneur with ruin. A striking example of such is the cooperation of legal firms with offshore companies. Why is such a partnership dangerous, what exactly can it lead to and how to avoid this problem? These are the questions that will be discussed in this article.

Basic information.

"Offshores" in our country are those enterprises that were registered in states with preferential taxation. For example - in Cyprus, Singapore, the Virgin Islands, etc. The characteristic features of the financial policy of most of these powers are:

1) The minimum number of taxes;
2) Refusal of the marching tax. In other words, the entrepreneur pays a strictly fixed amount in favor of the offshore country's budget. Regardless of the size of your own income.

The essence of the problem.

It would seem - what's wrong with working with a company that is registered in a state with such a loyal financial policy? At first glance, nothing. But if you look at this issue more closely, you can find a lot of "buts". Firstly, such firms in one way or another deceive their own state, depriving it of legitimate income. Which naturally arouses suspicion.

Secondly, many offshore companies maintain complete confidentiality of the financial affairs of their investors. That is, companies registered in such countries often have connections with criminals and use "dirty capital". It is not possible to check their honesty or find out where they got the money from.

Thirdly, suing an offshore company is not only difficult, but incredibly difficult. After all, the filed claim will be considered in another country. Let's think - are there many specialists in the Russian Federation who are well versed in international law and have experience in this field? Of course not. Accordingly, the cost of their services is at a consistently high level.

It is worth noting that such claims are considered for a very long time. In addition, many of them are rejected due to incorrectly executed documents. Finally, in many states there is a law according to which the losing party in court pays legal costs (the cost of lawyers, etc.).

How to determine whether an offshore company or not?

If you wish to find out the information you are interested in without involving specialists from outside, you are recommended to:

1) Examine all published information about your potential partner;
2) Send a request to various state services to obtain valuable data;
3) Give up on this matter and turn to professionals for help.

There are many good arguments in favor of the fact that self-definition "offshore" firms - it's stupid. Here are a few of them:

1) This process will take a long time;
2) No one guarantees that it will not be wasted;
3) Many answers can be obtained only by having the necessary contacts and access to places where ordinary citizens are not allowed;
4) Cooperation with professionals is more profitable from the financial side.

What kind of “specialists” are we talking about and what exactly can they offer an entrepreneur?

Nowadays, there are many Internet companies whose activities are related to the search for information and its analysis. They take some data from open sources, while others they get through the right contacts, loopholes in the law, etc.

What exactly do companies of this type offer?

A wide range of information regarding a particular company. With their help, you can get information about her:

1) The size of the authorized capital;
2) Confidence;
3) Profitability;
4) Liquidity;
5) Links with other enterprises;
6) balance sheet;
7) Stories;
8) Guides.
And many more.

How reliable are these companies?

It all depends on the specific artist. But in 90% of cases, there is no doubt about the data provided by them.

Summing up.

It is almost impossible to determine the "offshore" of a company on its own. Or at least difficult and expensive. But if you have firmly decided to check your future partner, there is a way out - you can turn to specialists from outside.

Bill to ban offshore companies from participating in procurement passed in the third reading

Additional requirements may be set for the procurement of consulting services

Only the Federal Assembly of the Russian Federation can officially explain the norms of Law N 44-FZ

Document: Letter of the Ministry of Economic Development of Russia dated February 23, 2015 N D28i-305

Key words: clarifications of the Law N 44-FZ; Ministry of Economic Development of Russia

Bill to ban offshore companies from participating in procurement passed in the third reading

Such companies will include legal entities if they are registered in the state or territory included in the list, which will be approved in accordance with paragraphs. 1 p. 3 art. 284 of the Tax Code of the Russian Federation.

Document: Draft Federal Law N 694962-6 (http://asozd2.duma.gov.ru/main.nsf/%28SpravkaNew%29?OpenAgent&RN=694962-6&02)

Adopted in the third reading by the State Duma

Guide to the contract system in the field of public procurement: more about procurement participants

Public Procurement: top news (http://www.consultant.ru/law/review/fed/fks2015-01-16.html): on the prohibition of offshore companies from participating in procurement

Keywords: offshore companies; ban on participation; Law N 44-FZ

Additional requirements may be set for the procurement of consulting services

From July 1, the Government of the Russian Federation received the right to determine additional requirements for participants in the procurement of consulting, as well as audit and audit-related services. This change was made to Art. 31 of Law N 44-FZ.

The method of procurement, in which it is possible to provide for these requirements, is not indicated. At the same time, relevant changes were made only to the norms of Law N 44-FZ, which regulate the holding of an electronic auction.

Due to the lack of the necessary Decree of the Government of the Russian Federation, the following question remains unresolved: is it possible to establish such requirements not only for an electronic auction, but also for other methods of procurement?

The Government of the Russian Federation received a similar right in the framework of procurement under Law N 223-FZ.

Document: Federal Law of June 29, 2015 N 210-FZ

Key words: audit and consulting services; Law N 44-FZ; Law N 223-FZ.

Only the Federal Assembly of the Russian Federation can officially explain the norms of Law N 44-FZ

Only such clarifications of Law N 44-FZ will have legal significance. This opinion of the Ministry of Economic Development of Russia is based on the Resolution of the Constitutional Court of the Russian Federation of November 17, 1997 N 17-P.

The explanations given by the ministry are not official and generally binding. They reflect the position of the department on the application of the provisions of Law N 44-FZ.

tax benefit— a decrease in the amount of the tax liability due, in particular, to a decrease in the tax base, obtaining a tax deduction, a tax benefit, applying a lower tax rate, as well as obtaining the right to a refund (offset) or refund of tax from the budget No. 53). Offshore companies- firms registered in offshore zones, which may set the goal of obtaining unreasonable tax benefits.

Submission by the taxpayer to the tax authority of all duly executed documents stipulated by the legislation on taxes and fees in order to obtain a tax benefit is the basis for obtaining it, unless the tax authority proves that the information contained in these documents is incomplete, unreliable and (or) are contradictory.

If the organization paying dividends is foreign, the established tax rate 0% (subparagraph 1 of paragraph 3 of article 284 of the Tax Code of the Russian Federation) applies to organizations whose state of permanent location is not included in the list of states and territories approved by the Ministry of Finance of the Russian Federation that provide a preferential tax regime for taxation and (or) do not provide for the disclosure and provision of information when conducting financial operations ( offshore zones).

Offshore company as a procurement participant- a legal entity whose place of registration is a state or territory included in the list of states and territories approved in accordance with subparagraph 1 of paragraph 3 of Article 284 of the Tax Code of the Russian Federation that provide a preferential tax regime for taxation and (or) do not provide for the disclosure and provision of information during the financial transactions (offshore zones).

Part 8 of Article 10 establishes that The Procurement Commission shall verify the compliance of procurement participants with the requirements specified in paragraph 1, paragraph 10 (except for the cases of an electronic auction, request for quotations and preliminary selection) of part 1 and part 1.1 (if such a requirement exists) of this article, and in relation to certain types procurement of goods, works, services to the requirements established in accordance with parts 2 and 2.1 of this article, if such requirements are established by the Government of the Russian Federation. The procurement commission has the right to check the compliance of procurement participants with the requirements specified in clauses 3-5, 7-9 of part 1 of this article, as well as during an electronic auction, request for quotations and preliminary selection with the requirement specified in clause 10 of part 1 of this article. The Procurement Commission is not entitled to impose on the procurement participants the obligation to confirm compliance with the specified requirements, except in cases where the specified requirements are established by the Government of the Russian Federation in accordance with parts 2 and 2.1 of this article.

That is, it is legislated that the commission is not entitled to impose on procurement participants the obligation to confirm compliance with the specified requirements.

According to the Letter of the Primorsky OFAS Russia dated March 28, 2016 No. 2042/03- Law No. 44-FZ prohibits participation in the procurement of legal entities whose place of registration is a state or territory included in the above list. Law N 44-FZ does not contain any reservations regarding the founders (offshore companies) of legal entities registered on the territory of the Russian Federation. Consequently, Law No. 44-FZ does not classify as offshore a company that is registered and tax registered in the territory of the Russian Federation, but the only participant (founder) is a foreign company (on the territory of an offshore zone).

Offshore zones in the field of taxation

The List of states and territories that provide a preferential tax regime for taxation and (or) do not provide for the disclosure and provision of information when conducting financial transactions (offshore zones) (approved by Order of the Ministry of Finance of Russia dated November 13, 2007 No. 108n) includes:

1. Anguilla;
2. Principality of Andorra;
3. Antigua and Barbuda;
4. Aruba;
5. Commonwealth of the Bahamas;
6. Kingdom of Bahrain;
7. Belize;
8. Bermuda;
9. Brunei Darussalam;
10. Republic of Vanuatu;
11. British Virgin Islands;
12. Gibraltar;
13. Grenada;
14. Commonwealth of Dominica;
15. People's Republic of China:

• Macau Special Administrative Region (Maomen);

1. Union of the Comoros:

• the island of Anjouan;

1. Republic of Liberia;
2. Principality of Liechtenstein;
3. Republic of Mauritius;
4. Malaysia:

• the island of Labuan;

1. Republic of Maldives;
2. Republic of the Marshall Islands;
3. Principality of Monaco;
4. Montserrat;
5. Republic of Nauru;
6. Curaçao and Saint Martin (Dutch part);
7. Republic of Niue;
8. United Arab Emirates;
9. Cayman Islands;
10. Cook Islands;
11. Turks and Caicos Islands;
12. Republic of Palau;
13. Republic of Panama;
14. Republic of Samoa;
15. Republic of San Marino;
16. Saint Vincent and the Grenadines;
17. Saint Kitts and Nevis;
18. Saint Lucia;
19. Separate administrative divisions of the United Kingdom of Great Britain and Northern Ireland:

• Isle Of Man;
• Channel Islands (Guernsey, Jersey, Sark, Alderney);

1. Republic of Seychelles.

Offshore zones in the banking sector

Bank of Russia Ordinance No. 1317-U dated August 7, 2003 approved the list of states and territories where offshore zones are located. The list is divided into three groups. The first is the most respectable. The second is less reliable and the third one requires serious reinsurance.