The importance of tax aspects for business is determinative, especially when choosing the type of transaction, behind which there is a choice of its structure and methodology.
International Tax Planning
The importance of tax aspects for a business is determinative, especially when choosing the type of transaction, behind which there is the expediency of the transaction being prepared, the choice of its structure and methodology. A businessman, when conducting specific financial transactions, always balances between commercial risks and tax risks. If the commercial risk is always within the competence of the business owner himself and his marketing managers, then the tax risk is entirely within the competence of his lawyers and tax specialists.
All businessmen want to be in tax security, but not everyone understands that tax security is determined by the right balance between possible tax benefits and tax risks.
Our specialists have invaluable practical experience in the field of international tax planning, some of them specialize in the Russian specifics of conducting business and their practice is “oriented” for Russian problems. The Russian specificity of the arising tax problems is very similar to the Eastern European countries that have recently become full members of the European Union. If Russian clients have learned to work with offshores more or less adequately, they take into account possible tax risks and do not make any really gross mistakes, then for planning and building the right international scheme which takes into account Russian realities they are not good enough. The task of a businessman is always the one to earn and keep his assets safe, and for this the tax aspects must be taken into account when choosing the structure of assets ownership, choosing the legal business model, protecting the assets to ensure the interests of inheritance, taking into account such factors as tax residency of the final beneficiary, the type of activity, the place of business, the location of the asset, the country of sale, and other emerging foreign and Russian current problems.
It is not a secret that the percentage of cases won by the tax authorities is growing every year, and tends to 90%. But there are interesting nuances in this large percentage of cases won by the tax authorities. Of course, the Russian tax authorities have learned to break up the simplest and patterned schemes with the use of transit companies or worthless marketing offshore agents and very well ascertains the identified draft dodgers. But beyond this success, their business does not go too much. Therefore, the number of won high-profile arbitration cases with non-residents is no more than ten per year. While the number of used non-resident companies in the schemes is hundreds of thousands.
It is well known that any more or less significant business in Russia often works not through one company. The connection between these companies may be “shown” or carefully hidden, but this is not the main thing! And most importantly, that these companies are quite definitely in active contact with each other (and with their founders). They communicate in different formats, pay each other, throw loans to each other and … DO NOT CONDUCT THE CASE TO THE END.
As a result, some companies of the group, over time, have huge debts to others (or to the founders). They are no longer able to repay these debts. In principle, no one expects this repayment. If not for one thing – BUT …
If debts are not extinguished (and do not require their return), then there is a non-operating income, from which taxes must be paid.
And no one surely wants to pay taxes, “for no reason at all”. Therefore, everyone is trying to solve this debt, close, minimize …
Another thing is that all this is done, often without money, using barter, bills of exchange or other offsets. This cannot attract the attention of the tax authorities. And, ultimately, it still leads to huge additional taxes and fines. And in especially unpleasant cases, it also leads to the emergence of subsidiary liability and real criminal cases. It is here that you just need competent clearing of accounts payables and receivables within a group of interrelated (and often affiliated and even related) companies.
And if the situations described above are relevant to you, then do not postpone the meeting with us and come. Believe that, you have something to discuss with us, and we have to offer you.
The international consulting center RPI Solutions specializes in solving legal, financial and tax issues of international level. One of the most important services for our customers that we provide is international tax planning, from simplified financial projects to rigorous circuit design. Let’s understand what this means in detail.
By contacting us for help, you will receive the most informative advice and qualified assistance of specialists at all stages of solving the problem with the international tax planning, and together we will solve all your questions with the exception of risk and with maximum benefit.