We provide a wide range of consulting services on various issues of corporate and personal taxation.
The advantage of our tax team is based on the combination of comprehensive technical knowledge and extensive practical experience.
Due to tax legislation complexity and ambiguity of law enforcement practice many companies justifiably choose to strengthen the financial department by appointing a Tax Manager. Tax Manager is involved in resolving all issues related to the application of tax legislation in order to minimize potential tax risks and optimize the aggregate tax burden. In order to tackle such complex issues efficiently, Tax Manager has to be highly qualified and adequately experienced.
By outsourcing Tax Manager function to us, you will be able to ensure efficient solution of any tax issues by a team of experienced and highly qualified experts including Partners, Directors and Managers. In case numerous complex issues have to be resolved on a tight schedule we could always reinforce the team by adding more specialists from our staff personnel.
The amount of fixed monthly fee for such services is comparable with the market level of monthly costs of keeping one such specialist on your staff. "Tax Manager" service provides a comprehensive tax support of your business, including:
- verbal and written consultations (unlimited number) on current issues related to application of the RF tax legislation;
- consulting on issues related to dovetailing accounting policy of the company to suit specifics of its business;
- analysis of contracts to be concluded with a view to identify any tax risks and drafting (editing) the relevant contractual provisions;
- assistance in drafting internal regulatory documents of the company;
- analysis of planned transactions in order to identify any tax risks and providing recommendations on how to mitigate identified risks;
- monitoring tax legislation and promptly informing the company about effective and forthcoming legislative changes that may influence tax liabilities of the company;
- expert support within the framework of desk and field tax inspections;
- drafting responses to tax bodies' decisions made based on tax inspection results, as well as drafting relevant appeals and statements of claim;
- participation in reviews of tax inspection results conducted by tax bodies;
- assistance in preparing terms of reference for tuning up tax functions of the automated accounting system;
- consulting support within the framework of upgrading tax calculation functions of the internal control system;
- participation in annual tax conferences organized by our firm and circulation of information materials on taxation issues.
You will be able to receive consultation and expert assistance on transfer pricing issues of any nature. In particular, among our services are:
- Preparation of documents on transfer pricing;
- Benchmarking – calculating market price intervals and profitability margin by operations (activity types);
- Assisting transnational companies in adapting their global transfer policies to Russian legislative requirements;
- Analyzing transactions in order to identify controlled ones;
- Optimizing business models in order to mitigate risks of transaction prices undergoing control;
- Developing a methodology for calculating market prices and assisting in its implementation;
- Expert support within the framework of tax audits of transaction prices and disputes with tax authorities;
- Drafting pricing agreements and comprehensive support during their signing.
We will ensure efficient protection of your rights within the framework of tax inspections and disputes with tax bodies. In particular, we provide the following services:
- Consulting support during tax inspections and pre-trial settlement of tax disputes (legal expert analysis of tax bodies' actions and decisions);
- Drafting responses to tax inspection reports;
- Representing clients in dealings with tax bodies within the framework of reviewing tax inspection results;
- Drafting appeals against tax bodies' decisions based on tax inspection results;
- Drafting statements of claim to be filed in court against tax bodies' decisions that took legal effect.
Tax consequences of any M&A are the key factor for investors as well as the sellers. Tax risks associated with the investment target as well as with the relevant M&A transaction may have substantial impact on the transaction price and forecasted financial indicators. We will help you to identify tax risks and ways to mitigate them within the framework of planned M&A, as well as within the framework of a special-purpose tax audit of the company. This service line includes the following services:
- Identifying pre-investment tax risks (possible tax saving opportunities) and relevant mitigation methods (opportunities for additional tax benefits);
- Tax structuring of transactions, expert support of integration events;
- Tax analysis of the current and planned financial model and providing recommendations on how to optimize it;
- We provide a comprehensive package of consulting services in the sphere of international taxation, including diagnostics of group structure and developing recommendations with account of past and forthcoming legislative changes in Russia, as well as in international taxation. In particular, we provide compliance assistance in respect of Russian "deoffshorization" legislation and OECD regulations against tax base erosion and profit shifting (BEPS). Our work in this sphere is based on a careful scrutiny of current law enforcement (arbitration) practice and is aimed at developing practical methods of mitigating possible tax risks.
- Efficient structuring of local and international investments;
- Developing an optimal ownership structure and operating model, including:
- initial investing and attraction of additional investments;
- structuring of financial flows;
- efficient repatriation of profit and reinvesting;
- issues of corporate governance and key personnel functions;
- using intellectual property;
- Focused diagnostics and developing methods of mitigating risks associated with the existing structures:
- Providing recommendations for ensuring the required level of presence of companies in foreign jurisdiction in order to decrease the risks of foreign companies being recognized as tax residents of the RF on the grounds of the "place of effective management" concept, as well as risks of tax bodies' refusal to apply tax benefits under international tax treaties on the grounds of the "beneficial owner of income" concept;
- Expert tax analysis of contracts and other documents, as well as drafting alternative provisions and developing document turnover procedures allowing to mitigate tax risks;
- Providing recommendations on efficient tying up of the corporate business structure with personal interests of individual investors.
Clients who are interested in ensuring full legislative compliance, as well as in decreasing tax burden and tax associated risks, entrust us the process of optimization of the relevant business processes. This service line includes:
- Unification of tax accounting methodology for all companies of the group;
- Optimization of tax accounting procedures and time period required for preparation of tax reporting;
- Setting up a system for tax risks assessment and mitigation;
- Building an organizational structure for the company tax service and allocating duties and responsibilities between tax department employees.
A foreign company - an organizer of international sports competition in Russia engaged us to provide consultation regarding tax consequences associated with payment of fees to foreign participants of competition.
Lack of a tax status in Russia prevented the company to pay Personal Income Tax by itself de rigore juris. As a result of a specially tailored approach we developed and approved with tax bodies, we were able to organize and ensure filing of tax returns and centralized tax payments.
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Our specialists identified terms and conditions of taxation and determined taxable market value of film industry products subject to customs duty when crossing customs borders of the Russian Federation (11 high-budget motion pictures) within framework of a litigation brought by RF Federal Customs Service against one of the largest film distributors in the RF.
A large oil company was in the process of purchasing several small regional oil fields. The client was interested in ensuring maximum transparency of the transaction and absence of hidden threats to its business.
Our specialists performed an integrated due diligence analysis in respect of 3.5 years preceding the transaction. The due diligence analysis identified potential tax, legal and ecological risks, which enabled the client to negotiate a significant discount off the asset's purchase price.
Management of a construction company involved in non-residential construction requested assistance of our company's specialists with the assessment of its tax accounting status and identification of possible risks of additional accrual of taxes by tax bodies.
Having analyzed the data provided, our specialists identified flaws in the company's tax accounting system, possible tax risks and suggested relevant mitigation methods. Our specialists also recommended changes in the company's business processes that would enable the company to optimize its tax burden and bring down amount of expenses that are non-deductable for profit tax purposes. Prompt implementation by the company of the proposed changes allowed the company to avoid accrual of additional taxes and fines, as well as to cut down its future tax burden.
Within the framework of preparing controlled transaction documents for a large international company manufacturing construction materials, possible scenarios were developed upon our recommendation for restructuring the product marketing model with account of current tax benefits and associated tax risks.
Upon consideration of proposed scenarios the client chose and implemented a solution optimal for its business and corresponding to its strategy and development goals.
A large multi-brand retailer and wholesale distributor of footwear and apparel in the Russian market engaged us to calculate arm's length range of the market in order to minimize Russian tax risks related to transfer pricing, as well as to prepare documents related to a controlled import transaction.
Within the framework of the task, we performed analysis of comparable companies and determined arm's length range. After the first stage of work was over and its results were approved by the client, we prepared documents in Russian and English language.
Upon discussing our deliverables on the level of the Russian and European offices, the client chose and implemented an optimal operational structure for its business in Russia and received justification for the market level of purchase prices used in the controlled transaction.
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