Taxes

• 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.

• 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.

• 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 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.

• 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.

• 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.

• 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.

• 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

• 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

• 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)