Because of the sanctions against Russian business currently in place, as well as the restrictive measures taken in response, businesses are forced to restructure the existing patterns and relocate from unfriendly states to friendly ones, as well as opening new markets: Asia, CIS countries, the Middle East.
We offer development of foreign holding, financial and trading structures for Russian businesses, including selection of jurisdiction and tax burden computation, analysis of existing foreign structures from the tax efficiency perspective, recommendations for restructuring a business with a foreign element, including mergers, liquidations and corporate migration of group members; analysis of the tax burden in the Russian Federation, including enforcement of CFC rules, the concept of beneficial income owner, tax residence of legal entities, tax at source when income is distributed within the structure, analysis of the existing and expected pool of linked contracts and financing structures for foreign business from the foreign-exchange legislation limitation viewpoint.
The BGP Litigation team has diversified experience and expertise not only in taxes but also in international law, and is experienced in working with foreign jurisdictions "from the inside", that is, it supports the project from concept development to project implementation, incorporation, corporate migration and dissolution of companies. This approach allows of projects to be realised from a corporate and civil law perspective, as well. Being lawyers and attorneys in the first instance, we understand how a client’s defence strategy against counterparties and government agencies should be constructed and, being tax consultants, we take this knowledge and experience into account in the context of tax specifics. This combination of international, legal and tax expertise makes us unique experts in this domain. The International Tax Planning Practice lawyers can meet any client’s needs, be on the same page with them and comprehend any of their questions.
The team has an extensive background of working with IT, FMCG, generating and natural resource extracting companies. Among other issues, the lawyers are experts in foreign exchange regulation and control, constantly monitor changes introduced by Presidential Decrees and the Clarifications adopted thereto, and can respond promptly to changes in the legislation, thereby mitigating the client’s risks.
The result of the work is tax burden optimisation throughout the chain, mitigation of the risks of being held fiscally and administratively liable (for foreign exchange legislation violation), ability to estimate the economic feasibility of doing business in a particular jurisdiction, as well as the to enter a new jurisdiction smoothly, without risk.