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.
Advising a major U.S. corporation on tax risks associated with an intragroup license agreement for an ERP system
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)
The client received an assessment of tax risks and recommendations for their minimization, as well as clear proposals for changing the contractual structure.
Analysis of the possibility of redomiciliation of a business entity in the ATS
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.
As a result of the analysis, the client was offered various jurisdictional options for the holding company within the Group.