Projects: Tax Law
- Developing a legal position for the Client in the course of an in-house tax inspection based on VAT declaration, resulting in denial of a VAT refund, and preparing objections to a tax inspection act.
- Advising on issues of relations with contractors in the course of transportation of goods for minimizing risks of disputes on unjustified tax benefit and denial of VAT deductions.
- Successful representation of a major shopping and entertainment center’s interests in courts of all instances during a dispute with a Moscow tax inspectorate regarding the issue of unlawful denial of a VAT refund.
- Successful representation of the Client’s interests during a dispute with a Moscow tax inspectorate regarding an issue of bad debt write-off from accounts of the tax authority.
- Advising on issues of possible tax risks in the course of implementing a developer’s project in the event of company reorganization, transfer of assets to a subsidiary, implementation of an investment contract, and a transaction with real estate.
- Advising clients on issues of tax consequences and best options for corporate and project financing.
- Advising on issues of double taxation, including issues of establishing permanent representative office for taxation purposes.
- Advising on taxation of controlled foreign companies, preparation of tax accounting related to the entity’s interest in a foreign company / controlled foreign company.
- Analysis of a license agreement for transferring the right to use computer software as to tax risks, advising on issues of VAT and income tax in such transaction.
- Advising on issues of controlling a market price level on transactions between interrelated entities on the part of tax and customs bodies, including advising a major clothes manufacturer on issues of tax and customs consequences of product sale in Russia through an interdependent subsidiary.
- Preparation of recommendations regarding provisions of employment contract with a general director being a foreign worker, as well as on guarantees and compensation while avoiding tax risks.
- Advising on issues of including terms and conditions into a supply contract, which pertain to payment of a bonus to a buyer for purchasing a certain amount of goods supplied, drafting the provisions of such contract.
- Advising on issues of profit distribution, taxation, as well as on issues of financing the activity of subsidiary and dependent companies (loan agreements, issues of thin capitalization, making contributions into assets without increase of charter capital).
- Support in the course of a field tax inspection of the Client, including preparation of employees for questioning by tax inspectors, advising on the Client’s issues and obligations in the course of inspection, development of the Client’s legal position on disputable issues regarding land tax payment, as well as calculation and payment of personal income tax, and preparation of objections to the tax inspection act.
- Successful representation of the Client’s interests during an in-house tax inspection in a dispute on receipt of unjustified tax benefit by the Client in the course of cooperation with forwarding companies, as a result of which the higher tax authority approved a VAT refund.
- Representation of the Client’s interests in a court dispute with a tax inspectorate on unlawful denial of a VAT refund due to claims regarding the VAT rate applicable to transport and forwarding services in the course of organizing international shipping of goods.
- Development of the Client’s legal position during a field tax inspection on issues of the tax inspectorate’s claims regarding payment of personal income tax when employees receive financial benefit, preparation of objections to the inspection act, as well as appeal of a decision, following which the decision was made in the Client’s favor.
- Development of legal position for the Client being a major international manufacturer of insulation materials within the framework of a field tax inspection on a dispute on obtaining unjustified tax benefit and denial of VAT deductions; representing the Client during pre-trial settlement, including preparation of objections to the inspection act and appeal to higher tax authority; advising in the course of additional control measures, including contesting expert assessment conducted by the tax authority, as well as subsequent preparation for filing a lawsuit, including application for security measures in form of suspending the effect of the disputed inspectorate decision, accepted by the court in the Client’s favor.
- Advising the Client being a manufacturer of automated systems for city and railway transport during a field tax inspection, development of legal position for the Client concerning tax claims on the company’s due diligence in choosing suppliers of services/works and cooperation with contractors who in the tax authorities’ opinion were acknowledged unreliable.
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