International tax planning
Structuring a business using foreign jurisdictions
Developing or reviewing corporate structures that use foreign jurisdictions, analysis of asset ownership, dealings with foreign companies and income allocation.
Analysis of the applicability of double tax treaties and assessment of the overall tax burden. Recommendations to reduce tax risks and optimise the tax burden, taking into account legislation, case law and the position of the tax authorities.
Synergy Audit analyses the tax consequences of international structures
Ownership structure
Developing and reviewing structures for holding assets through foreign companies, tax burden at every level
Payments to foreign companies
Withholding tax on dividends, interest, royalties and other income of foreign organisations (Articles 309 and 310 of the Tax Code of the Russian Federation)
Double tax treaties
Applicability of treaties, beneficial ownership and tax residence, consequences of the suspension of certain treaty provisions by Presidential Decree No. 585 dated 8 August 2023 and of the denunciation and termination of certain treaties
Permanent establishment
Risks of a foreign organisation creating a permanent establishment in Russia (Article 306)
Tax residence
Recognition of foreign organisations as Russian tax residents (Article 246.2) and its tax consequences
CFCs and controlling persons
Obligations of controlling persons of controlled foreign companies
Recommendations take into account legislation, case law and the position of the tax authorities. The result is a tax opinion and an action plan to reduce tax risks and optimise the tax burden.