KIAP lawyers have completed a tax structuring project of an international group of companies.
Considering that over the past three years Russian and international tax legislation have undergone significant changes, KIAP lawyers have carried out a complex work on reassessing the approaches of a foreign holding to structuring its business activities in Russia.
This project has become unique due to the simultaneous assessment and alignment of the requirements of international, European and Russian legislation within the perimeter of one group of companies. During this project KIAP lawyers analyzed the business activities of the international group of companies taking into account the requirements of the OECD plan to combat the erosion of the tax base (BEPS), the automatic exchange of information and the work of the Russian VAT-2 system, as well as the latest approaches of law enforcement to the permanent representation of foreign companies in Russia, the concepts of the actual right to income and unjustified tax benefits.
Within the analysis the aspects of the international and national legislation of Russia, Switzerland and Luxembourg were involved.
The interests of the Principal on the project were represented by the partner Andrey Zuykov.