Tax consulting
Services include:
  • Assessment of tax implications of prospective deals (agreements).
  • Tax structuring as part of M&A deals and reorganization:
    • аssessment of tax risks inherent in existing structure;
    • development of a tax efficient framework, including international tax planning;
    • аssessment of tax implications of various approaches to asset transfer and financing;
    • сalculation of a tax burden and an effective tax rate for a group of companies.
  • Development of a tax strategy for a group of companies, tax function management.
Tax consulting and tax assessment
FBK Legal provides multi-format support to the medium and large-size businesses in tax, from one-off verbal and documented advice to a full-scale customer support on a long-term basis, including:
  • advice on all types of tax and duties,
  • advice on assessment and payment of social contributions (Pension Fund of the Russian Federation, Social Insurance Fund of the Russian Federation, Federal Compulsory Medical Insurance Fund),
  • advice on collection of customs charges (VAT, duties, determination of a customs value),
  • practical workshops on advanced tax issues, including relations with tax authorities,
  • advice on accounting,
  • methodological support and IT solution issues,
  • assistance in completion of tax returns,
  • elaboration of draft legislation and/or analysis of legislative initiatives in tax,
  • expert outlook on law enforcement developments for the upcoming periods,
  • R&D projects on the order of government authorities and corporations.
Tax due diligence
Tax and legal audit conducted by FBK Legal rests on detailed rules and a well-defined framework, is regularly updated to account for recent developments in law enforcement and includes:
  • Verification of accounting records:
    • evaluation of accounting policies and approaches in place,
    • verification of source documents.
  • Tax risks assessment:
    • applied tax optimization framework,
    • financing practices,
    • results of documenting corporate procedures,
    • marketing campaigns (discounts, bonuses, premiums, etc.),
    • applicable agreements and document workflow framework,
    • tax technicalities.
  • Legal evaluation of:
    • possible field tax inspections,
    • economic rationale of incurred expenses,
    • justified tax benefits,
    • possible tax claims,
    • chances for appealing a court award/tax authorities’ requirements.
Elaboration of guidelines and accounting policies
The FBK Group experts have provided services in elaboration of a methodological framework for tax and accounting practices, including:
  • Elaboration of accounting policies:
    • for tax purposes (FBK Legal);
    • for accounting purposes (Accounting Consultancy Department).
  • Elaboration of standardized documentation:
    • unified chart of accounts;
    • reference of business operations;
    • forms of registers, reporting and other document workflow.
  • Preparation of Terms of Reference for application of IT-based solutions on the basis of existing accounting policies:
    • development of a tax programming technique for automatic tax calculation function within the budgeting system;
    • integration of IT application results into the ERP system used at the entity.
International tax
  • Tax structuring of international deals.
  • Assessment of tax implications of movement of goods and cash internally across international business units.
  • Tax structuring of corporate structures:
    • development of a framework for financing, dividend payment, license payments (royalty), international freight, etc.;
    • assessment of tax risks inherent to Russia’s environment stemming out of foreign shareholder agreements;
    • tax assessment of the status of the Russian branch of a foreign entity;
    • tax assessment of implications of activities pursued by foreign entities in the territory of the Russian Federation;
    • support in establishing an international holding structure (including KYC procedures, preparation and execution of a set of documents required to establish the holding).
  • Advice on the application of a double taxation treaty.
  • Advice on tax and corporate legislation of the most popular jurisdictions in international planning.
  •  Advice on deoffshorization issue, including tax issues associated with controlled foreign entities.
Tax litigation
Going through tax inspections.
The entities which are getting ready to go through an on-site tax inspection and the entities which are going through immediate on-site tax inspections can rely on FBK Legal support in:
  • preliminary tax due diligence;
  • check of documents to be submitted (also for awareness purposes) to the inspection officer;
  • verification of legality of a tax inspection;
  • instructions to the entity’s staff on the interaction with the inspection officer, submission of documents, presentation of clarifications, etc.;
  • evaluation of tax authorities’ requirements (inquiries, ordinances and other documents);
  • negotiations with tax officials and police officers;
  • evaluation of chances for a dispute resolution on the basis of the tax inspection report.
Pre-trial protection
At a pre-trial stage we provide:
  • evaluation of a tax inspection report;
  • preparation of objections against a tax inspection report;
  • representation of clients’ interests in considering the findings of the tax inspection at the tax office’s premises (participation in the objections);
  • representation of clients’ interests in considering the materials of additional tax control measures, preparation of objections;
  • evaluation of the tax authorities’ award based on the findings of the tax inspection;
  • evaluation of legality and propriety of tax claims;
  • appealing the tax authorities’ award at a higher-level authority, preparation and submission of a complaint, monitoring of the complaint’s status;
  • preliminary evaluation of required interlocutory injunction.
Dispute resolution
  • development of a case strategy;
  • collection of evidence;
  • preparation of process documents;
  • representation of clients’ interests at the enforcement proceedings stage;

Tax credit / tax refund

Transfer pricing
  • advice on transfer pricing and advice for consolidated groups of taxpayers;
  • calculation of prices for tax purposes;
  • evaluation of a pricing framework in place and tax risks assessment;
  • regulation of business processes to ensure compliance with new pricing control rules;
  • introduction and application of IT-based solutions to the developed regulations;
  • preparation of statutory documents;
  • protection in tax litigation.
Tax monitoring

Tax monitoring

  • Analysis of the current state of the internal control system for the purposes of tax monitoring
  • Drafting recommendations for the transition to the tax monitoring regime
  • Implementation of measures for the transition to the target level of maturity of the internal control system for the purposes of tax monitoring
  • Drafting a document on the establishment of the organization’s internal control system
  • Drafting the Information Interaction Regulation
  • Interaction with the tax authority. Preparation of documents for the transition to tax monitoring
  • Performing a set of works to automate information exchange with the tax authority or methodological support for the company in the process of automating interaction with the tax authority (if automation is carried out by the IT specialists of the customer himself or by an integrator)


Tax support for four eurobond issues
Preparation of comfort letters for the eurobond issue prospectus
Tax support for a gas transmission system construction project
Comprehensive tax support for the investment activities of the company within the gas transmission system construction project
Guidance support for compliance with article 54.1 of the Tax Code of Russia
Preparation of a set of documents and control procedures aimed at compliance with the conditions of article 54.1 of the Tax Code of Russia when making transactions and ensuring effective protection of taxpayers
Tax support for a $26.8 billion transaction
Tax and financial support of a group of companies in a merger with a petrochemical holding
Tax structuring of a RUB 4.8 billion transaction
Tax structuring of an acquisition of the largest unmanned aerial vehicle manufacturer
Tax support for group restructuring
Comprehensive tax support in the course of a project for restructuring of the Russian part of a group — a leading international technology supplier
Support of a global IT company for its transition to tax monitoring
Full support for transition to tax monitoring using the developed software solution
Tax support for corporation’s contract work
Support of a large international company to preventively assess and minimise tax risks at the stage of execution of contracts with both Russian and foreign counterparties
Challenging the results of a field tax audit of a company
Successful protection of a company’s interests in a tax dispute over the company’s compliance with the requirements of tax legislation on cross-border transactions and with the requirements of article 54.1 of the Tax Code of Russia
Representation of a group of companies in $300 million disputes over TP
Protection of the interests of big mining, transport, and service companies in tax disputes over transfer pricing
Successful defence of a company in a dispute with a taxation authority
Representation in a dispute over the validity of the business model of the company’s activities, absence of violations of the TP rules in coal supplies
Pre-action settlement of a precedent-setting dispute over VAT payment in the field of maritime navigation
Representation of a large Russian shipping company in a dispute with a taxation authority over VAT taxation
Changing the structure of relations in an international group of companies
Tax support of a leading electronic musical instrument manufacturer and distributor in the course of changing the structure of supplies to Russia
Preparation of a company for transition to tax monitoring
A comprehensive project for a large group providing for the client’s transition to tax monitoring
Restructuring of a group of companies in connection with the adopted legislation on deoffshorisation
Diagnostic assessment of the structure of a group due to changes in the tax legislation in terms of the taxation of profits received by controlled foreign companies and income received by foreign entities
Tax and legal support in calculation and substantiation of the rate classification for TP purposes
Elaboration of an efficient rate formula for cost planning to minimise tax and antitrust risks
Successful challenging in court of additional taxes amounting to more than $1 million
Representation of subsidiaries of the largest grain exporter in Russia before commercial courts
Tax support for restructuring of a group of companies
Preparation of recommendations on the group restructuring in connection with the adopted law on deoffshorisation
Challenging taxation authorities’ claims in relation to investment activities
Representation before commercial courts in a number of precedent-setting cases concerning groundless claims by taxation authorities in relation to the investment activities of group companies
Defence in a tax dispute amounting to RUB 800 million
Successful protection of a company’s interests in the Presidium of the Supreme Commercial Court of Russia
Representation of the company in a number of cases due to the refusal of the Pension Fund of Russia to accept reports
Successful pre-action and court representation of a company — a world leader in prompt service, formation of an important precedent in a dispute with the Pension Fund of Russia
Elaboration of a TP guide for a large Russian group
Elaboration of a transfer pricing policy for more than 50 groups of Russian and international transactions


Russia implements Tax changes in respect of IT industry
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