In the context of global exchange of tax information and Russian deoffshorization, the services for international tax planning are nowadays becoming ever more relevant than ever. Introduction of the CFC rules, fast development of judicial practice for a beneficial owner of income, limitation of benefits under international agreements - all this makes a taxpayer to take a different look at his/her business structure. We help our clients find effective decisions in the era of deoffshorization.
In particular we provide the following services for international tax planning:
Analysis of the existing asset holding structures concerning the tax efficiency and potential risks, providing recommendations to reduce the identified risks, including those related to the Russian deoffshorization laws
Development of taxwise effective holding, financial and trade structures, that meet the major business targets of the client
Diagnostics of the foreign private capital ownership structures in order to determine the tax consequences for CFC
Preparation and submission of all necessary accounts and documents to tax authorities of the Russian Federation
Creation of personal asset holding structures (including trusts, foundations, etc.)
Foreign companies incorporation support
Preparation of foreign companies to dissolution, implementation of preferential dissolution in the Russian Federation
Consulting on capital amnesty, support for declaration of assets and income of individuals from foreign sources.
Performance of risks analysis of the Group structure and development of effective restructuring plan from the tax point of view. Based on the results of restructuring, international structure of the Group was reduced from 20 to 5 holding companies.
The Group's Management requested assistance with regard to the analysis performance concerning the groups of companies restructuring related to the dissolution of foreign companies. The analysis included the issues of the part of assets transfer inside the group in order to make the best use of them, advising on the issues of the CFC rules application to foreign companies of the group, calculation of foreign companies' profit for the CFC purposes and application of adjustments to them, recommendations on tax risks minimizing.
Also, the Group's Management was interested in rendering the legal assistance by the BGP lawyers in the support for the CFC tax-free dissolution procedure and tax declaration of these processes in the Russian Federation.
The analysis of tax consequences and risks was performed, the step-by-step plan of actions (the Road Map) which are necessary for the transition to the target structure was developed.
The notices on participation of the group's foreign companies in the international group of companies were prepared and timely submitted to tax authorities for the purposes of the country-by-country reporting (CbCR).
The group of companies restructuring was made, which allowed to reduce the living expenses of the group. Also, the tax-free dissolution of some companies and the transfer of foreign assets to the Russian Federation were carried out.