Tax support for the creation and operation of a large investment partnership
The client required advice on a wide range of tax issues, including taxation of IT exit, IT financing using various instruments, distribution of profits, sale of assets, etc. The consulting was carried out at all stages, including the process of IT creation and operation. The work on this project was complicated by the specifics of IT taxation and included analysis of a significant volume of various transactions, including barter transactions, loans, assignment of rights of claim and transfer of debts, as well as other ones. (The project was implemented by an employee before joining Tax Compliance)
The client received ready-made solutions on the issues of interest and a map of tax consequences of IT activities. Tax consulting on this project was complicated by the presence of many unresolved issues of IT taxation in Russia, for each of which the client was able to provide effective solutions.
Defending the interests of a major generating company in a dispute over the treatment of "golden parachutes" as expenses for corporate income tax purposes.
During the tax period under audit the Company paid remuneration to employees for voluntarily agreeing to terminate an employment contract. This remuneration was included in expenses for corporate income tax purposes. The tax authority considered these expenses to be economically unjustified, which led to a tax dispute. (Project implemented by employee before joining Tax Compliance)
The legal position and calculations prepared on the basis of the emerging jurisprudence made it possible to substantiate the illegality of a significant amount of additional charges within the episode. This project was successfully implemented during the most difficult period of time when the practice on accounting of the respective payments as expenses was heterogeneous and contradictory.
Supporting a dispute over retrospective application of the results of cadastral value revision in the interests of a major generating company
At the end of 2016 the Moscow authorities decided to revise the value of a number of key facilities and to make its application retroactive. The Company did not agree to pay corporate property tax for 2016 based on the recalculated value, which led to a dispute with the tax authority. (The project was implemented by an employee before joining Tax Compliance)
As a result of developing the right strategy, based on the position of the Supreme Court of the Russian Federation in the case of Yumaks, we were able to convince the court of the legitimacy of the client's claims.
Supporting a dispute over the exclusion of production buildings of one of Russia's largest generating companies from the list of immovable property for which the tax base is determined as the cadastral value
A number of buildings of the energy company were used for purposes related to production activities, both directly and indirectly, in particular to accommodate personnel, etc. These buildings were included in the list as a result of a survey of their actual use by the regional authorities, as well as taking into account the permitted use of the land plot. (Project implemented by an employee prior to joining Tax Compliance)
In this dispute, we were able to convince the court to exclude all buildings from the list, allowing the client to achieve substantial tax savings.
Working out optimal ways of tax accounting of marketing activities for a large British technology company
In this project the client was given the task to develop a marketing policy, the inventory of existing marketing activities and development of optimal ways of tax accounting of these activities. The project concerned interaction with bloggers and celebrities, bonus payments, outdoor advertising and advertising in shopping malls, commercial product testing, etc. (The project was implemented by an employee before joining Tax Compliance)
Marketing policy was developed for the client, taking into account the recommendations to optimize tax risks. The client also received a detailed description of the tax consequences and accounting methods of the relevant transactions.