Advice on taxation of CFCs

Advice on taxation of CFCs

  • Successfully
    Advice on taxation of CFCs

    Support of the client at the stage of advising on payment of taxes from CFC profits, as well as assistance in preparing a tax amnesty declaration

    Services were rendered to the beneficiary of a construction company for retrospective disclosure of information on participation in a controlled foreign company and on the existence of bank accounts opened outside the Russian Federation.

    • Industry

      Construction

    • Process description

      At the time of drawing up and submission of notifications to the tax authorities the statute of limitations under p. 1 of Article 129.6 of the Tax Code had not expired, i.e. the client still had the risk of tax liability for untimely disclosure of information about the CFC. In order to exclude tax liability for failure to submit CFC notifications for previous tax periods, the client was provided with services to prepare a special tax declaration allowing to apply the tax amnesty under the Federal Law of May 29, 2019 № 110-FZ within the voluntary declaration of their assets. Also within the framework of the project we assessed the grounds for the absence of an individual's obligations to withhold personal income tax from the profit of a CFC.

    • Result

      As a result of legal defense, tax liability and penalties for late submission of CFC notifications due to the application of tax amnesty provisions were avoided

    • Employees involved

      Anastasia Garipova, Yulia Pavlova