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Legal division

Tax and Currency regulation

We propose our assistance in tax disputes by means of resolutions both in pre-trial and trial proceedings. Our specialists provide for tax support in the context of ordinary activity of the company and also apply unconventional approach in tax structuring and defining an appropriate tax base to benefit while concluding contracts.

A key advantage of RBS in the area of tax and currency control is the close interaction of lawyers and financial consultants. The rich experience of specialists helps to apply a non-standard approach to solve problems and protect the interests of clients, subject to elimination of possible risks.

We provide support in any issues related to taxation, currency regulation and control, by providing services that cover:

  • tax advice on the application of legislation on income tax, VAT, corporate property tax, personal income tax, land taxes, etc.
  • application of legislation on special taxation regimes
  • appraisal and mitigation of tax risks
  • tax planning and optimization subject to the requirements of Russian and foreign legislation
  • taxation of the group of companies including taxation of transactions (e.g. M&A)
  • taxation of transactions on capital market 
  • analysis of corporate costs to decide on the possibility of allocating them to expenses in general and regarding specific tax periods in particular
  • legal support during desk and visit tax audits, including analysis of legislation and primary documentation, drafting answers to the requests of the tax authorities, assistance in the selection of documents, preparation of objections and appeals to higher tax authorities, development of positions, determination of a strategy for during audits, etc
  • advising on transfer pricing and currency regulation
  • analysis of the existing business model of the company, assessment of its tax consequences in the Russian Federation and in foreign countries, suggesting alternative solutions
  • analysis of the structure of interest and dividend payments and suggesting more effective solutions
  • determination of a road map for mergers and acquisitions using foreign holding companies
  • structuring the activities of a foreign investor in Russia in the context of current taxation rules and tax preferences
  • structuring the activities of Russian companies to enter foreign markets, including choosing the most favourable jurisdiction for the registration of a holding company, including offshore jurisdictions
  • supporting investment projects from the initial stages of its realization
  • elaboration of possible instruments for investing in foreign markets both from Russia and through Western European holding companies that are part of the Russian group of companies 
  • tax assistance in projects related to the acquisition by Russian companies of assets abroad, particularly the acquisition of real estate and securities
  • advising Russian companies on tax issues in conducting transboundary trade operations
  • analysis of transactions in context of currency legislation related risks 
  • preparation of documents for currency control proceedings 
  • participation in disputes with state authorities
  • representation of client’s interests in disputes with state authorities of currency control
  • other consultancy services
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