Practices Sectors Private clients

International Tax Planning

International Banking and Finance ←
→ Intellectual Property and Technology

Products

In the context of global changes in the ways of doing international business, a competent approach to international tax planning becomes especially important. Limitation of benefits under international treaties, difficulties in making cross-border payments, development of CIS, Asian and Middle East markets - all this makes a taxpayer look at the business structure in a different way.

BGP Litigation lawyers help clients find effective solutions in the era of changes related to international taxation issues: lawyers offer solutions for non-standard situations that arise in the course of foreign trade or investment transactions, redomiciliation of companies, develop tax-efficient solutions for both large holdings and high net worth private clients. Among the practice's competitive advantages is the ability to take a comprehensive approach to a client's task by engaging lawyers from different areas of expertise - specialists in sanctions, customs, labour law, family law and inheritance planning, international payments, transportation and asset financing, etc.
Services
Analysis of Existing Asset Ownership Structures for Tax Efficiency and Risk Assessment, with Recommendations on the Russian Deoffshorisation Legislation
Development of Holding, Financial and Trade Structures that are Tax and Currency Efficient and Aligned with the Client’s Key Business Objectives
Selection of Foreign Jurisdictions for Relocation of Both Beneficiaries and Their Families, as well as Their Businesses
Assistance with Redomiciliation, Restructuring, and Liquidation of Foreign Companies
Assessment of Foreign Asset Ownership Structures to Determine Tax Implications Under CFC Rules and to Explore Tax Relief Opportunities for Repatriating Capital to Russia
Creation of Personalised Asset Ownership Structures, Including Trusts, Personal Funds and More
Preparation and Submission of All the Requisite Reports and Documents to the Russian Tax Authorities
Consultations on Currency Regulation Restrictions for Cross-Border Payments and Investment Activities

Products

We advised:

A Major Clothing Manufacturer

on identifying tax and currency risks in the current business structure and developing an optimum structure for the group company for the brand to enter global marketplaces, the UAE and Turkish markets

Owner of a Major Marketplace

in Moscow on tax and currency implications and risks in relation to the requirements for repatriation of earnings, preventing and countering tax base erosion, profit shifting rules and personal tax implications for the beneficiary

Representation of a Private Swiss Bank

on Russian taxation with the aim of minimising the risks of double taxation in Russia, including other tax issues related to banking activities

A Foreign Supplier of Coke-Chemical Products

on issues related to analysis of options for restructuring the existing asset holding structure in terms of tax and currency risks in the Russian Federation and abroad

A Leading Russian Development Company

in connection with developing a strategy for passing an on-site tax audit and tax control conducted in connection with reorganisation of the company

Private Clients of an Investment Company

on preventing and countering tax base erosion and profit, tax-free liquidation of foreign companies and corporate restructuring, capital amnesty, as well as assessment of the risk of foreign companies being recognised as Russian tax residents

A Russian Investment Company

on tax-free liquidation in relation to more than 20 CFCs with subsequent submission of all the requisite documents to the Russian tax authorities

An Agricultural Producer

on tax and currency implications and risks in incorporating a foreign company with the intention of raising investments in the wheat production sector, as well as in connection with analysis of the financing structure with the participation of a foreign legal entity from the perspective of the current currency restrictions

An Oil Producing Holding Company

with majority foreign participation on incorporation of a new holding company in the Middle East, as well as on the tax implications of the group’s target structure, including restrictions under the currency legislation when restructuring assets with participation by companies from unfriendly states

Manufacturer of Fibre-Reinforced Plastic Rebar

on tax implications when registering a holding company in the UAE, acquiring subsidiaries in the USA, China, Kazakhstan, Saudi Arabia and the UAE, financing the group's activities at the level of Russian and foreign shareholder individuals through capital holdings and debt investments, tax burden recommendations

A Russian Management Company

on the tax and currency implications of opening a subsidiary in the UAE, as well as providing capital or debt investments in its favour for the purpose of subsequent investment in subsidiaries in the UAE and Switzerland

A Drilling Company

as part of analysis of tax and currency implications for the purposes of restructuring the group's companies

Team

Alexander Golikov
Partner, partner committee member, attorney — Tax Advise and Disputes
Pavel Kondukov
Partner, attorney — Tax Advise and Disputes

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