Services Tax practice

Tax practice

Tax support for complex projects and M&A transactions:

• Tax structuring of complex infrastructure projects
• Develop projects to restructure Russian and international company groups, inter alia, using foreign jurisdictions
• Tax structuring of investments and transactions to sell stocks, interests and real estate
• Tax modeling
• Comprehensive due diligence on tax issues
• Develop an accounting policy for taxation purposes

• Pre-trial appeal against actions and decisions of tax agencies
• Challenging tax agencies’ decisions at all court levels
• Enhance the position in a tax dispute:
• Initiate and support concurrent arbitrations
• Arbitrazh court disputes with counterparties on issues of VAT recovery

• Analyze the lawfulness of document discovery by the tax agency
• Analyze the consequences of submitting or the failure to submit documents to the tax agency
• Prepare responses to demands on submitting documents (information)
• Legal support during questioning at the tax agency
• Defend against the unlawful actions of the tax agency

• Taxation of certain operations:
• Ownership of certain assets
• Application of tax relief and other tax preferences
• Assist in the implementation of projects
• Legal advice on transfer pricing issues

• Develop texts of draft laws and regulations regarding taxation
• Develop texts of queries to Ministry of Finance of Russia, and track receipt of an individual clarification

• Advise on application of double taxation treaties between Russia and other states
• Structure foreign assets for purposes of tax optimization:
• Select the optimal jurisdiction
• Select the company’s legal form
• Assist in implementation of projects
• Due diligence regarding tax issues of representative offices and branches of foreign companies in Russia
• Conduct tax disputes concerning the tax assessment of foreign companies and representative offices:
• Advise with regard to field tax audits at all phases
• Represent clients’ interests in court proceedings

• Identify whether there are grounds for notification of tax authorities
• Identify whether foreign companies and ventures may be recognized as tax residents of Russia
• Develop strategies to reduce the cumulative tax burden and risks for businesses using foreign companies and other entities
• Simplify foreign corporate structures and minimize aggregate administration costs