According to Article 14-2.1. of Tax Code of the Republic of Azerbaijan for taxation purposes, the profit of an enterprise that is not considered a resident of the Republic of Azerbaijan and is registered in countries (territories) with preferential taxation shall be subject to taxation in the Republic of Azerbaijan in the following cases: 
14-2.1.1. If a person considered a resident of the Republic of Azerbaijan, either individually or jointly with a resident or non-resident person with whom it is mutually affiliated, directly or indirectly holds more than 50 percent of the voting rights in the foreign enterprise, or more than 50 percent of its charter capital, or the right to receive more than 50 percent of the profit of that foreign enterprise;
14-2.1.2. If the actual tax paid on the profit of the controlled foreign enterprise is equal to or less than 75 percent of the profit tax that should have been paid on that profit in accordance with this Code;
14-2.1.3. If more than 30 percent of the annual income of the foreign enterprise consists of the following types of income:
14-2.1.3.1. Interest derived from financial assets;
14-2.1.3.2. Royalties derived from intellectual property;
14-2.1.3.3. Income derived from the sale of shares and equity interests;
14-2.1.3.4. Income derived from financial leasing;
14-2.1.3.5. Income derived from insurance, banking, and other financial operations;
14-2.1.3.6. Income derived from enterprises that generate income from goods and services without creating any economic value.