Restructuring of a group of companies in connection with the adopted legislation on deoffshorisation

Restructuring of a group of companies (combining 10 foreign companies with about $2 billion income) in connection with the adopted legislation on deoffshorisation

Diagnostic assessment of the structure of a group due to the adoption of changes in the tax legislation in terms of the taxation of profits received by the controlled foreign companies and income received by the foreign entities; preparation of recommendations for changing the structure of the group: change in the jurisdiction of several companies of the group, merger of the companies within the group, recognition by the foreign companies of the tax residence in the Russian Federation, intercompany settlements, and other possible changes. The restructuring led to a reduction in the administrative burden in the group of companies, the restructuring of intercompany debts, and the effective optimisation of intercompany settlements.