Cases

Cases

  • Retail Successfully
    Tax Audit

    Advising a major U.S. corporation on tax risks associated with an intragroup license agreement for an ERP system

    • Process description

      The client planned to enter into a license agreement between the U.S. parent company and a Russian subsidiary for an expensive ERP system. A large "security dossier" was prepared for this agreement in order to present it to the tax authorities during an audit. The consultant was given the task of assessing the key tax risks related to the above transaction, as well as to research the weaknesses of the security dossier and formulate recommendations on strengthening the client's position. (The project was implemented by the employee before joining Tax Compliance)

    • Result

      The client received an assessment of tax risks and recommendations for their minimization, as well as clear proposals for changing the contractual structure.

  • Production Successfully
    Redomicilation in the SAR

    Analysis of the possibility of redomiciliation of a business entity in the ATS

    Various jurisdictional options for the holding company within the Group are proposed

    • Employee involved

      Nikita Zharov

    • Process description

      The team was tasked with selecting the best jurisdiction for the holding company within the Group. The team analyzed various jurisdictions for opportunities to create / relocate a holding company within the Group. As part of this analysis, including the possibility of redomiciliation of the business in the ATS was considered.

    • Result

      As a result of the analysis, the client was offered various jurisdictional options for the holding company within the Group.

  • Construction More than 50 millions ₽
    Tax reserves

    Supporting the client (owner of one of the largest shopping malls in Moscow) in challenging the cadastral value of the property

    The tax provision for corporate property tax was identified and the process of reducing the cadastral value of the property was passed

    • Employee involved

      Nikita Zharov

    • Process description

      The client was interested in finding tax reserves for corporate property tax. The team identified an opportunity to reduce the cadastral value of the property, helped collect the necessary evidentiary basis and accompanied the legal process of contestation.

    • Result

      As a result of the lawsuit, the cadastral value of the property was reduced by more than 25 percent. The tax savings for the client amounted to more than 50 million rubles.

  • Pharmaceuticals Successfully
    Advising on the application of tax legislation

    Analysis of tax risks associated with the possible qualification of the nature of the Group's business (federal pharmacy chain) as a "split" business scheme

    Recommendations were prepared to change the structure of economic relations within the Group in order to comply with the requirements of Article 54.1 of the Tax Code of the Russian Federation

    • Employees involved

      Mikhail Begunov, Nikita Zharov

    • Process description

      The team had the task to analyze the nature of the Group's activities for the risks of imputing the scheme of "splitting" the business. The team analyzed: (1) circumstances of business entities within the Group in terms of meeting the conditions for the application of special tax regimes; (2) circumstances of creation of certain business entities; (3) specifics of business relationships within the Group.

    • Result

      Based on the results of the analysis, the risks of qualifying the nature of the Group's activities as a "split" business scheme were identified and recommendations for changing the structure of business relationships within the Group were developed.

  • Pharmaceuticals Successfully
    Support in the framework of pre-test analysis

    Supporting the client (international pharmaceutical manufacturer) in the pre-testing analysis on the interaction with the "technical" organization

    The tax authority decided not to conduct an on-site tax audit of the taxpayer

    • Employee involved

      Nikita Zharov

    • Process description

      As part of the pre-inspection analysis, the tax authority concluded that the taxpayer had accounted for tax purposes for business transactions with a "technical" company. In view of the above, the taxpayer was invited to conduct an independent analysis of tax risks and (if necessary) to adjust its tax liabilities. The team analyzed business transactions with the disputed counterparty for tax risks and subsequently helped the client to prepare a response to the request of the tax authorities and collect the evidence, confirming: (1) the reality of business transactions with the disputed counterparty, (2) the reality of the obligations under transactions directly claimed by the counterparty, (3) the counterparty has no attributes of "technical" company for tax purposes.

    • Result

      The tax authority accepted the arguments of the taxpayer, and decided not to conduct an on-site tax audit against him.