Advice on complex tax issues
Well-founded solutions to complex and contentious tax issues
Advice on complex and contentious issues in applying tax legislation, including assessment of the tax consequences of specific operations and transactions.
Well-founded tax opinions that take into account legislation, case law and the position of the tax authorities, to support corporate decisions and defend the position in dealings with the tax authorities.
Synergy Audit prepares tax opinions on complex and contentious issues
Non-standard transactions
Tax consequences of complex transactions, operations with securities and participatory interests, gratuitous transfers of property
Ambiguous rules
Analysis of unclear provisions of legislation, conflicting guidance of the Ministry of Finance and the Federal Tax Service, and case law
Tax risks
Assessment of the likelihood of tax claims and the amount of possible additional taxes, penalties and fines
Written clarifications
Preparing requests to the Ministry of Finance and the Federal Tax Service and support in obtaining clarifications
Position for an audit
Arguments to support the position in a tax audit or dispute, selection of case law
Transactions and projects
Tax review of investment projects and transactions at the structuring stage
A tax opinion sets out an analysis of the facts, applicable rules, guidance and case law, a conclusion and a risk assessment. It is used to support corporate decisions and to defend the position in dealings with the tax authorities.