Tax system in Russia is a complex and fast developing one and it is hardly possible to carry on a successful business in Russia without assistance of a qualified tax expert. Our lawyers will be glad to help you with the following major tax issues:

  • Advising on the available forms of setting up a business in Russia;
  • Tax efficient structuring of contractual relations between a foreign parent company and a Russian subsidiary and their Russian customers and suppliers / contractors;
  • Tax efficient optimization and reorganization of international structures considering existing network of international treaties on avoidance of double taxation (Double Tax Treaties);
  • Assistance in resolution of tax disputes with Russian tax authorities, from appealing tax rulings with tax authorities to defending clients in courts at all court levels;
  • Russian CFC rules;
  • Advising on off-shore structuring, foreign trusts.

Transfer Pricing

Transfer pricing has become a matter of particular concern to international companies operating in Russia through subsidiaries or branches. Any controlled cross-border transaction may be subject to transfer pricing regulations and scrutiny on the part of the Russian tax authorities. Our lawyers have extensive experience in advising on and preparing transfer pricing documentation, including advising on the following matters:

  • Applicability of transfer pricing rules;
  • Electing the most appropriate method of transfer pricing;
  • Functional analysis;
  • Comparability analysis;
  • Determining arm’s-length range;
  • Preparing transfer pricing documentation;
  • Developing transfer pricing strategy.

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