Nowadays, one of the key elements of successful international company is the ability to pay taxes correctly. Each year the standards and regulations of international taxation become more and more strict. Lawyers that are informed about the latest changes in tax regulation around the world are the valuable asset for you company’s prosperity and growth. We have wide experience in tax audit of transnational taxation, transfer pricing. Our lawyers are aware of latest developments in BEPS, OECD MAA, and FAFT Regulations.

Tax support for complex projects and M&A transactions:

  • Tax structuring of complex infrastructure projects
  • Develop projects to restructure Russian and international company groups, inter alia, using foreign jurisdictions
  • Tax structuring of investments and transactions to sell stocks, interests and real estate
  • Tax modeling
  • Comprehensive due diligence on tax issues
  • Develop an accounting policy for taxation purposes

Conducting tax disputes:

  • Pre-trial appeal against actions and decisions of tax agencies
  • Challenging tax agencies’ decisions at all court levels
  • Enhance the position in a tax dispute:
    • Initiate and support concurrent arbitrations
  • Arbitrazh court disputes with counterparties on issues of VAT recovery

Advice with regard to tax audits:

  • Analyze the lawfulness of document discovery by the tax agency
  • Analyze the consequences of submitting or the failure to submit documents to the tax agency
  • Prepare responses to demands on submitting documents (information)
  • Legal support during questioning at the tax agency
  • Defend against the unlawful actions of the tax agency

Tax advice:

  • Taxation of certain operations:
    • Ownership of certain assets
    • Application of tax relief and other tax preferences
  • Assist in the implementation of projects
  • Legal advice on transfer pricing issues

Develop draft laws and obtain clarifications:

  • Develop texts of draft laws and regulations regarding taxation
  • Develop texts of queries to Ministry of Finance of Russia, and track receipt of an individual clarification

International taxation:

  • Advise on application of double taxation treaties between Russia and other states
  • Structure foreign assets for purposes of tax optimization:
    • Select the optimal jurisdiction
    • Select the company’s legal form
    • Assist in implementation of projects
  • Due diligence regarding tax issues of representative offices and branches of foreign companies in Russia
  • Conduct tax disputes concerning the tax assessment of foreign companies and representative offices:
    • Advise with regard to field tax audits at all phases
    • Represent clients’ interests in court proceedings

Legal advice on regulatory issues within the Customs Union, Common Economic Space and the World Trade Organization

“Deoffshorization” advice

  • Identify whether there are grounds for notification of tax authorities
  • Identify whether foreign companies and ventures may be recognized as tax residents of Russia
  • Develop strategies to reduce the cumulative tax burden and risks for businesses using foreign companies and other entities
  • Simplify foreign corporate structures and minimize aggregate administration costs