Developing a step-by-step business restructuring plan, including the repayment of intragroup liabilities and liquidation of “excess” foreign companies;

• Coordination of liquidation of foreign companies (termination of nominal ownership), including interaction with service providers, liquidators, etc.;
• Assistance in applying tax exemption with regard to income from liquidation of CFCs (the so-called “tax-free liquidation”).

The clients’ business structure was significantly simplified, the clients received a number of significant assets in their personal ownership, which is optimal from the standpoint of taxation and estate planning in the current situation.

• Comprehensive advice to a client owning a Russian business through a group of offshore structures and companies (Cyprus, BVI) on “tax-free liquidation” and the second phase of capital amnesty, coordination of service providers, liquidators, assistance in application of “through taxation” provisions by Russian group companies.
• Analysis of a foreign investment insurance program in terms of applicability of Russian law provisions on controlled foreign companies (CFCs) to the insurance product, development of additions/amendments to the program’s General Regulations.
• Advising the client on participation in capital amnesty in 2019, restructuring of assets for the purposes of filing a special declaration under capital amnesty, preparation of 3-NDFL declaration, as well as special application for tax exemption of assets received by the beneficiary from the liquidated company from taxation.
• Advising a client on declaration of foreign assets by filing a special declaration under the voluntary declaration of capital and property located in foreign countries.
• Analyzing the specifics of tax residency under the law of a number of European countries (e.g., Belgium, Germany) and structuring the client’s business in the most favorable tax environment, while maintaining the business in Russia, with the client’s actual presence in Europe.