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.
Delivery of legal services for one of the major fast-food chains in Russia with regard to the comprehensive tax analysis of the intellectual property items ownership as well as development of holding and financial structure of the Group.
The Group's shareholders applied for the comprehensive tax advice for the analysis of tax consequences and risks in relation to the efficient structuring of intellectual property items ownership, in particular, the trademark.
A necessity was identified to carry out the structure analysis for compliance with the current tax legislation of the Russian Federation aimed at the Russian economy deoffshorization (the CFC Rules, the Beneficial Owner, the tax residency of companies).
Also, within the project it was required to perform the intra-group indebtedness restructuring.
The extensive analysis of tax consequences and risks when performing the various options of the Group's structure restructuring was carried out.
The most efficient strategy was proposed from the tax and business point of view.
The most efficient holding structure of the Group was developed.
The optimal structure of the intellectual property rights ownership was developed.