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Tax

  • Cross-border tax issues for family offices and private clients.
  • Assessing the tax consequences of planned structures and advising on tax compliance issues.
  • Structuring of transactions involving international assets of private clients, including reduction of the tax burden in line with the existing legislation.
  • International tax planning.
  • Advice on CFC matters, support of compliance with tax obligations of CFC controlling person.
  • Advising on automatic exchange of tax information.
  • Advising on tax residency.
  • Preparation of tax returns for individuals.
  • Advising on currency and tax law compliance in connection with cross-border transactions.
  • Advising on tax issues in foreign jurisdictions.
  • Advising foreign private investors and foreign family offices on Russian tax issues.

Examples of projects

Tax
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”).
Result:

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.

Other Projects

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.

Other Projects

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.

All cases

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