All cases: Tax
Tax
- Analysis and performance of all necessary actions for the client in connection with disclosure of foreign assets in the course of “capital amnesty”. (including as part of the first, second and third amnesties), as well as in meeting the requirements of Russian law on CFCs.
- Coordinating the liquidation of foreign companies (termination of structures) controlled by the client, including interaction with service providers, liquidators, etc;
- Assisting in applying tax exemption with respect to income from CFC liquidation (so-called “tax-free liquidation”);
- Advising on application of Russian double taxation treaties and assistance with implementation of so called “pass-through taxation”.
- Simplifying the corporate structure of the client’s business, which also allowed the client to obtain a number of significant assets into personal ownership, as well as the ability to apply “pass-through taxation” with respect to dividends received from the client’s Russian business.
- Advising clients owning Russian manufacturing and trading businesses through a group of nominees and companies (Cyprus, BVI, Belize, Montenegro) in connection with comprehensive consulting;
- Arranging all necessary actions for the disclosure of foreign assets during the so-called “capital amnesty” and in compliance with Russian CFC legislation;
- Analyzing the tax, currency and other legal consequences of changes in the corporate structure of the business and developing a step-by-step restructuring plan, including the settlement of intragroup liabilities and the liquidation of “excess” foreign companies;
- Coordinating the liquidation of foreign companies (termination of nominal ownership), including interaction with service providers, liquidators, etc;
- Analysis and advice in connection with the application of tax exemption with respect to income from the liquidation of CFCs (so-called “tax-free liquidation”).
