Our team of experienced professionals will help you resolve tax issues at all stages of your international project and assist in implementing the most effective solutions.
OUR SERVICES
Restructuring of ownership, supply chains and cash flows
- We can help you adapt to new restrictions, maintain business operations and redistribute your business among legal entities
- We can help you apply business restructuring methods that have proved successful in the new environment
- We share our expertise in using new supply chains and our thorough understanding of customs nuances
Analysis of the implications and risks of various cross-border transactions, structures and operations
- We can help you do a country comparison for purposes of selling or splitting up a business and raising or restructuring financing, taking into account restrictions that apply internationally
- We share our best practices with clients in terms of friendly jurisdictions for trade and financing in view of tax and legal nuances
Consulting on withholding tax in Russia and benefits afforded by tax treaties
- We can help you apply the lowest withholding tax rate and obtain refunds of overpaid tax in even the most complex cases
- We assist with tax planning for international payments to and from Russia, taking sanctions and currency restrictions into account
- We help assess the degree to which benefits under tax treaties can be relied on in the new circumstances
Consultations on obtaining permits from the Government Commission for Oversight of Foreign Investments
- We explain the complex procedures for transaction approval, dividend payouts and loan repayment, drawing on our track record of successful solutions
- The application process involves many practical nuances that we can help you plan for
Support for foreign companies redomiciling to Russia and other countries
- We assist companies, including holding companies, in redomiciling from different countries to special administrative regions of Russia and to other friendly jurisdictions. We can help in complex cases where direct redomiciliation is unfeasible
Support during tax audits covering international operations
- We help clients successfully navigate tax audits in Russia and other CIS countries as well as many countries around the world, keeping new country restrictions in mind
Consulting and reporting under CFC rules
- We enable quick and accurate reporting under CFC rules, taking into account new restrictions applicable outside Russia (including audit restrictions), and we do it at affordable prices
Analysis of the business impact of BEPS and BEPS 2.0 (Pillar II)
- We have a thorough understanding of the BEPS (2015) and BEPS 2.0 (2022) action plans to prevent base erosion. We help our clients assess the impact of these plans in specific countries and take appropriate actions
TAX MESSENGER
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New format approved for notifications of controlled transactions
On 20 August 2024 a draft order of the Federal Tax Service on amendments to Order No. MMV-7-13/249@ of the FTS of 07.05.2018 “Concerning Approval of the Form of a Notification of Controlled Transactions…” (“the Draft”) was published on the federal portal of draft laws and regulations.
24.09.2024
Individual permit to export goods in light of retaliatory export restrictions imposed by Russia
Many cross-border traders face the need to ship goods out of the EAEU for a variety of reasons, such as equipment repairs, sales to foreign counterparties, and so on. However, for over two years now Government Decree No. 311 of 09.03.2022 has imposed a ban on the export of a large range of goods (currently over 200 items). That ban is in place until 31 December 2025.
30.08.2024
The deadline for filing Notifications of Membership of MNE Groups for 2023 is imminent
We would like to draw your attention to the fact that the deadline for submitting Notifications of Membership of a Multinational Enterprise Group (MNE Group) for 2023 expires on 31 August 2024 for MNE groups whose fiscal year coincides with the calendar year.
29.08.2024
The business splitting amnesty – pros and cons
In this article we will address the questions of what business splitting actually is, what the legislator is proposing, how the amnesty will be implemented in practice, the factors that need to be considered in deciding whether to take part in it and what is needed for that purpose.
24.07.2024
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Bill on the implementation of tax policy objectives – a summary of key provisions
On 8 July 2024 the text of Bill No. 577665-8 “Concerning Amendments to Parts One and Two of the Tax Code of the Russian Federation and Certain Legislative Acts of the Russian Federation Concerning Taxes and Levies” was published in advance of its second reading in the State Duma.
19.07.2024
The tax reform law has been signed by the President. How does the final version look?
On 12 July 2024 the President signed Federal Law No. 176-FZ (“the Law”) approving the proposed amendments.
16.07.2024
Non-preferential rules of origin. Current trends in customs control
In accordance with Article 29 of the EAEU Customs Code, proof of the country of origin of goods is required where the application of tariff measures, prohibitions, restrictions and safeguard measures to protect the domestic market is dependent on the origin of goods. For customs purposes, the country of origin is confirmed either by a declaration of origin or by a certificate of origin of a good.
18.06.2024
Inclusion of transportation costs in the customs value of goods. Overview of relevant case law
The issue of whether freight forwarding costs for the transportation of goods within the customs territory of the EAEU should be included in customs value has been a regular subject of court disputes with customs authorities over the last few years. Here we highlight one of the most recent court rulings on this subject, which went in favor of the foreign trade company involved.
14.06.2024
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Presidential Decree No. 767: key changes
New Presidential Decree No. 767 On Amendments to Certain Decrees of the President of the Russian Federation was published on 9 September 2024 to amend three regulatory acts. The main changes relate to transaction procedures, accounting for and performance of obligations under Eurobonds and replacement bonds which had persons from unfriendly states in their holding chain, as well as the procedure for permits to be obtained by Russian companies to pay profits to persons from unfriendly states.
17.09.2024
The business splitting amnesty: uncertainties arising from the bill
On 3 June 2024 the Ministry of Finance of Russia presented the State Duma with a bill amending Parts One and Two of the Tax Code of the Russian Federation and certain other legislative acts of the Russian Federation, which includes, among other things, a proposal to grant an exemption from taxes, fines and penalties for offences relating to business splitting that were discovered over the period 2022-2024.
06.06.2024
