Tax-support

Anastasia Arzhanova, Nikita Zharov

The client's activities are related to the IT sphere. In order to apply tax benefits, the client was interested in obtaining IT accreditation with the Ministry of Digital Development of Russia, as well as in analyzing the list of services to be provided by the client to its customers to ensure that they correspond to the services whose revenue is taken into account for the purposes of applying IT business tax benefits.

During the implementation of the project, Tax Compliance specialists: (1) analyzed the client’s business activities for compliance with the requirements for accredited IT companies; (2) accompanied the client in the process of collecting documents (information) and obtaining state accreditation in the field of IT; (3) analyzed the list of IT services provided by the client; (4) developed taking into account the peculiarities of private office work, the mechanism for documenting the provision of confirmation of IT services; (5) assessed and proposed an appropriate procedure for forming the cost of IT services taking into account the client’s business processes.

Mikhail Begunov, Nikita Zharov

The Client was considering the possibility of separating the IT function from the management company structure within the Group into a separate legal entity. In this regard, the Client was interested in analysing (1) the corporate structure of the Group for risks of claims related to the "split" of the business; (2) the business contracts of the newly established IT Company for compliance with the requirements of tax legislation in terms of the application of tax benefits for IT companies.

In the course of the project implementation Tax Compliance specialists: (1) conducted a comprehensive analysis of interaction between the Group and IT-companies and prepared proposals for adjusting the corporate structure in order to reduce risks in terms of "splitting" the business; (2) developed proposals for adjusting the provisions of the agreement in order to ensure its compliance with the requirements of tax legislation in terms of applying tax benefits for IT-companies.

Mikhail Begunov, Nikita Zharov

The client purchases certain goods from suppliers, on the sale of which the suppliers apply a reduced rate of VAT. The client subsequently sells these goods as part of its own business activities, subjecting them to a VAT rate of 20%.

The client was interested in analysing the possibility of applying a reduced VAT rate when selling the said goods, as well as the mandatory legal requirements that the client needs to comply with in order to achieve the said objective.

As a result of the project, the Tax Compliance team managed to assess tax risks associated with the application of the reduced VAT rate for the Client and to suggest ways to minimize them.

In particular, in the course of the project Tax Compliance specialists: (1) analyzed documentation relating to the products sold by the client; (2) developed proposals on changing the document flow in order to apply the reduced VAT rate.

Mikhail Begunov, Nikita Zharov

The client applied for the purpose of identifying and assessing tax risks that may arise in the course of realisation of transactions with shares in the charter capitals of the Companies.

The Tax Compliance team conducted due diligence in connection with planning transactions with shares in the authorised capital of the Companies. The key feature of the project was the assessment of the impact on tax consequences of the presence of a substantial amount of retained earnings on the balance sheet of the Companies, which were planned to be distributed immediately after the acquisition of shares by the Client. As a result of the project, the Tax Compliance team assessed for the Client the tax risks that may arise in connection with the transactions. In particular, in the course of the project implementation Tax Compliance specialists: (1) conducted comprehensive due diligence of transactions; (2) assessed the possibility of reclassification of transactions by the tax authority; (3) structured the planned transactions taking into account the tax consequences of their execution.

Mikhail Begunov, Nikita Zharov

When selling products, the customer uses a customer loyalty bonus program. Under the said loyalty program customers accumulate bonuses, with which they can later pay up to 100% of the cost of purchased products. The client was interested in the analysis of tax risks and procedure of registration of cash receipts in case of full payment of the cost of production by purchasers with bonuses.

As a result of the project realization Tax Compliance team managed to assess tax risks related to VAT and income tax for the Client and to suggest the ways of their minimization. In particular, in the course of the project Tax Compliance specialists: (1) analyzed the Client's loyalty bonus program; (2) developed proposals to minimize the risks associated with the recognition of such sales of goods for bonuses as a gratuitous one.