Tax

Expertise

Services on corporate tax advice:

• Tax structuring of transactions, including M&A transactions
• Tax advice on financing subsidiaries, including cross-border transfer of assets and expenditures under intra-group agreements
• Advising on issues arising in the course of a company’s activity, including VAT, profit tax, property tax and personal income tax
• Tax audit: analysis of company documentation, assessment of potential tax risks and options to minimize them
• Advising on international structuring of activities and assets, including deoffshorization and controlled foreign companies (CFCs), as well as application of double tax treaties

---

Services on protection of clients’ interests in disputes with tax authorities:

• Developing contractor vetting policies to confirm due diligence in cooperation with counterparties
• Training for company heads and employees on proper cooperation with regulatory authorities
• Legal support and advice during in-house and field tax inspections
• Support in tax disputes at the pretrial stage before higher tax authorities and representation in courts of all instances
• Development of defense strategies and representation in tax crime cases

---

Services in the course of tax inspections:

• Analysis of prospects and risks based on submitted documents
• Support during control measures, including assistance during interrogations
• Training for employees on cooperation during tax inspections and interrogations
• Preparation of responses to requests from tax authorities and drafting of necessary documents
• Appeal through court, if necessary
• Support in tax disputes at the pretrial stage before higher tax authorities and representation in courts of all instances
• Development of defense strategies and representation in tax crime cases

---

International tax structuring:

• Business structuring with consideration of tax and foreign currency aspects:
  • Recommendations on selecting appropriate jurisdictions for doing business
  • Analysis of tax consequences and development of tax-efficient structures, taking into account applicable benefits and international treaties
  • Financial structuring and distribution of financial flows
  • Ensuring asset protection and beneficiary anonymity
  • Analysis of sanctions and foreign currency risks
  • Recommendations on optimal structures and risk minimization
• Customs structuring:
  • Assistance in documenting export and import supply chains
  • Analysis of restrictions on import and export of certain goods
  • Advising on available customs preferences and preferential regimes
• Support for incorporation of companies in various jurisdictions
• Opening accounts and making payments, including recommendations on jurisdictions for account opening (subject to KYC requirements), remote account opening, and ensuring control over accounts when structuring through nominal participants

---