Assessment and organization of corporate, financial, and contractual structures in the light of the general requirements of the Russian tax legislation, preventing tax abuse (Article 54.1 of the Tax Code of the Russian Federation), and the current practice of applying double taxation treaties.
Providing of legal support in compliance processes related to special regulations applied to prevent tax abuse in international activities: legislation on controlled foreign companies, transfer pricing, and thin capitalization.
Conducting tax investigations and tax due diligences (audits) of companies and their counterparties in the course of various transactions upon request of the owners.
Analysis of contractual structures, including intra-group agreements, for tax risks and options to eliminate such risks.
Development and support of the implementation of current internal policies, including policies for checking counterparties, accounting for certain categories of expenditures, and regulating intragroup transactions.
Advising international electronic service providers, who supply Russian customers, on registration with Russian tax authorities and VAT payment.
Assisting private clients and legal entities with tax and currency control reporting.
Developed and provided legal support for the Russian office of a European engineering company for the implementation of an internal policy on checking counterparties for their good faith.
As part of an international M&A transaction, carried out a tax investigation for a large Italian consumer goods manufacturer, including an analysis of tax compliance of the Russian main distributor structure and an analysis of the risks of recognizing the distributor group companies as mala fide taxpayers and their application of tax avoidance schemes.
Conducted a tax due diligence (audit) for the Russian office of an international pharmaceutical company to identify tax risks arising from the reorganization of the group's companies.
Advised one of the world's largest online retail stores on the compliance of an international project to launch an online platform for the sale of software with the requirements of Russian tax law.
Analyzed the tax risks of the current contract arrangement for a Russian pharmaceutical company and provided support in developing a new contractual structure and recommendations for working with counterparties.
Supported an international recruiting agency providing digital services to Russian customers on registration with tax authorities.
Advised one of the leading South Korea energy companies on business structuring and supplies to the Russian Federation, including issues connected with permanent establishment, VAT, transfer pricing, and currency exchange regulation.