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.
We rendered consulting services on tax matters to the private clients. Throughout the year, the client’s concerns related to the impact of the Russian deoffshorisation rules on personal and business structures of its clients. The majority of its clients were interested in consulting services on the amnesty of capital, as well as on disclosing foreign assets (accounts, companies, property) to the Russian tax authorities.
In 2019, the second wave of capital amnesty came to a close, that allowed to legalise foreign assets and bank accounts and avoid criminal, tax, and administrative law sanctions. The majority of clients benefitted from this opportunity, allowing the company to transfer the clients’ foreign assets from their foreign accounts and foreign brokers into the management of our client.
Analysed the structure of the clients’ foreign assets for violations of the Russian foreign currency and tax laws, and advised them on minimising the risks found by correctly disclosing and/or restructuring assets;
Supported tax-free liquidations of over 50 controlled foreign companies followed by the disclosure of individuals holding them in the Russian Federation;
Filed over 100 special returns under the capital amnesty, disclosing information on the clients’ accounts with foreign banks, foreign companies, securities, real estate and other assets;