Cases

Cases

  • energy 40 million ₽
    Court settlement of tax disputes

    Supporting a dispute over retrospective application of the results of cadastral value revision in the interests of a major generating company

    • Process description

      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)

    • Result

      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.

  • energy Successfully
    Court settlement of tax disputes

    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

    • Process description

      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)

    • Result

      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.

  • Retail Successfully
    Tax Audit

    Working out optimal ways of tax accounting of marketing activities for a large British technology company

    • Process description

      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)

    • Result

      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.

  • 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.