ALRUD Tax team conducts consulting services in all aspects of Russian tax law. We are engaged in providing ongoing consulting services to our clients, both corporate and individual, with respect to various taxation matters arising from all sorts of transactions. Our tax experts are engaged in projects from almost all practices (Corporate, Banking & Finance, Restructuring & Insolvency, Real Estate and Labour) accompanying general advice with explanation of tax consequences of the proposed path.
in ICC dispute against largest German heavy plate producer on collection of damages for more than EUR 150 mln arising from one of the major energy-related projects in Russia. ALRUD tax team provided tax opinion for the London arbitration court to support the Client in collecting part of the damages which included indirect taxes paid by the Client.
on the tax incentives and special investment regimes available for foreign investors developing coal business in the Far East of Russia. ALRUD tax team supported the client in drafting a set of framework agreements on development of a coal deposit and negotiations with the Russian regional authorities on provision of tax and customs benefits and possibility to support the client during conclusion of an advanced transfer pricing agreement with the Russian tax authorities.
in litigation with two former employees of a Russian branch claiming that the client made excessive tax withholdings from their income by applying incorrect tax rates. ALRUD tax team developed an effective defense strategy and drafted procedural documents that allowed the client to prevail in the dispute. All claims of ex-employees were dismissed entirely.
in relation to infrastructure projects, connected with building, or reconstruction, of highways in Russia. ALRUD tax team advised the client on the most effective tax structure for financing the projects, considering tax risks and tax implications arising from the provision of the low-rate loans and assignment of rights in respect to the existing loan debts.
on Russian aspects of the global purchase agreement, covering transfer of printer business over 50 jurisdictions and assisted with all tax matters related to completion of the asset transfer deal in Russia. ALRUD tax team drafted and negotiated the tax-related clauses of the agreements underlying the deal and advised the client on various tax matters connected with the deal (VAT, accounting matters, etc.).
in the sale of its controlling stake in the company owning an oil service terminal and on the establishment of a JV with the major Russian oil company.
on structuring of business activities in Russia and various tax aspects, including advising on tax risks connected with the Permanent Establishment issues, VAT, transfer pricing and currency control regulations. Additionally, ALRUD tax team drafted two requests to the Ministry of Finance and the Federal Tax Service of the Russian Federation in order to obtain their clarifications on disputable tax issues, in order to protect the client from future tax claims.
in attracting investment from the direct investment fund operating in Russia. ALRUD tax team supported the client on group restructuring and provided recommendations re. the most effective tax structure for investments, including restructuring of existing debts with the lowest tax risks, advising on tax implications connected with thin capitalization and CFC rules.
in assess of the tax risks and tax implications connected with creation of a Permanent Establishment (PE) in Russia. ALRUD analysed the structure of the client’s business in Russia and CIS, advised on steps required to reducing tax risks of the previous periods and elaborated a new structure of carrying out business in Russia and CIS, without PE risks for the client. As a result, the client decided to restructure its business in Russia.
on establishment of a JV in Russia, including assessment of the tax risks related to the transfer of assets and further sale of JV, or its assets, VAT issues connected with in-kind contributions, etc.
on structuring and cross-border tax issues, related to the purchase of a stake in the large Russian energy business. This includes advising on the withholding tax on dividends and interest and capital gains issues, as well as application of the “beneficial owner” and the “look-through” concepts.
on the tax issues related to its Funding Swaps and Repurchase Transactions, with the basis of Russian equities and derivatives. This included advising on the structuring of such transactions and application of the Principal Purpose Test (PPT) under the Multilateral Convention (MLI).
during its on-site tax audit, related to the justification of transfer of the tax losses to future periods and accounting for the interest expenses on loans, issued for the development of the project.
during the tax due diligence, which was aimed at checking two competing companies in the market, prior to their merger with our Client's subsidiary, and advised on the steps necessary to mitigate the resulting tax risks.
on structuring the broadcasting agreement for the online broadcasting of the hockey matches, with a leading technology company in Russia, including advising on issues related to the VAT on e-services and withholding tax on royalties.
on the tax incentives and special investment regimes available for the foreign investors, developing a coal business in the Far East of Russia. ALRUD’s tax team supported our Client in drafting a set of framework agreements on the development of a coal deposit and negotiations with the Russian regional authorities, on the provision of tax and customs benefits and the possibility to support our Client, during the conclusion of an advanced transfer pricing agreement, with the Federal Tax Service of the Russian Federation.
during its multinational project on launching an online marketplace, for the sale of the software. ALRUD’s tax team assessed the tax implications and provided advice on structuring the agreements and Client’s business in Russia, from the tax law perspective.
during the sale of its controlling stake in the company, owning an oil service terminal and on the establishment of a JV with a major Russian oil company.
in relation to the tax investigation, which was aimed at investigating the distribution network of a Russian independent distributor. This included more than 50 companies from different regions of the Russian Federation. Our Client was interested in the tax investigation’s results to make a final decision on the acquisition of one of the leading European groups of companies,which produces hair care products.