Corporate restructuring
Tax support for structural changes and reorganisations
Tax support for projects changing the structure of a group, including reorganisation, reallocation of assets, and changes to the legal structure and financial flows.
Determining the tax burden of the target structure, analysing tax risks and making recommendations to reduce them, taking into account legislation, case law and the position of the tax authorities.
Synergy Audit supports changes to group structure at every stage
Reorganisation
Tax consequences of mergers, accessions, divisions, spin-offs and conversions, succession to tax obligations
Reallocation of assets
Transfers of property within a group (contributions to property and charter capital, sales, profit distributions) with a calculation of the tax consequences
Target structure
Calculation of the tax burden of the target structure and comparison of options, choice of tax regimes for group companies
Financial flows
Intragroup loans, dividends, services and royalties, transfer pricing in the new structure
Business purpose
Supporting the business purpose of the changes and reducing the risk of recharacterisation under Article 54.1 of the Tax Code of the Russian Federation
Valuation and accounting
Valuation of the assets and interests transferred, accounting for reorganisation transactions
The work includes analysis of the current structure, development and comparison of options, an implementation plan and support after the changes. Recommendations take into account legislation, case law and the position of the tax authorities.