Cases

• 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.

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.

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.

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.

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.