We secured property tax exemption for the client

Client: Rosseti Moscow Region PJSC

Industry: Energy distribution

Issue: The tax authority refused in granting tax benefits, having acknowledged a range of movable property items as real estate assets. We had to appeal the results of in-office tax audit with the commercial court.

Our work included: We protected the client’s interests in the Moscow Region Commercial Court and discovered improper attachment of evidence during the audit. Federal Tax Service Directorate for Moscow Region reversed the appealed decision on its own, and the Tax Inspectorate was forcing the client to abandon the action. Abandonment could have resulted in adverse consequences, and the decision of the Tax Inspectorate was successfully appealed in court.

Result: Disputed items were registered as movable property, and the client was exempted from property tax on these items.

Transfer of foreign assets to Russia in the background of sanctions

Industry: Investments into construction

Issue: The client sought transfer of foreign assets into Russia, namely, shares in Russian and foreign companies, units in investment funds, and receivables from Russian and foreign entities.

Our work included:
• we developed a transaction structure with the most favourable taxation system for the client, and considering Decrees of the President of the Russian Federation on sanctions;
• in scope of the 4th stage of capital amnesty, we prepared a special declaration and a notification on controlled foreign entities;
• we identified necessary documents to exercise income tax benefits for receipt and subsequent sale of assets.

Results: The assets were transferred to the client in complete compliance with sanction laws. He received valid tax instruments to declare income in form of assets and reduce taxable base for the subsequent sale. The client was also provided with a protection portfolio in case of potential claims of tax authorities.

Twofold reduction of charges based on the results of on-site tax audit

Client: Research and Development Enterprise Architecture, Engineering, Assembly LLC

Indutry: Installation of security systems at large restricted access facilities

Issue: The client was unsatisfied with the certificate of on-site tax audit. We had to appeal this document.

Our work included: We assessed appeal prospects, studied available evidence, and prepared additional objections to the audit certificate.

Result: Preparation of proper evidence and effective interaction with the tax authority allowed to reduce charges twofold.