Tax Consulting and Structuring

Tax Consulting and Structuring

  • Assessing personal assets and income structure for tax and currency risks, developing recommendations to eliminate identified risks
  • Structuring personal wealth to achieve multiple objectives (asset protection, investment performance, capital accumulation and preservation, predictable estate structure, etc.)
  • Corporate tax planning and structuring
  • Designing a structure of real estate ownership in Russia and abroad using corporate and other instruments
  • Tax and legal structuring of Russian and cross-border transactions (sale and purchase of real estate, shares and participatory interest in companies, cryptocurrencies and other digital assets, etc.)
  • Analyzing potential implications of automatic exchange of financial information for clients and their business
  • Assistance in KYC/AML procedures for clients and interaction with compliance departments at banks and other financial institutions

Tax and Currency control regulation

  • Advising on any issues of personal taxation in Russia and abroad, as well as currency control regulation in Russia
  • Advising on new currency control regulation issues, such as evaluating legality of foreign account transactions, cross-border transfers and transactions with foreign securities and real estate
  • Preparing annual tax returns and reports required by the Russian tax and currency control law
  • Auditing personal finances for tax and currency risks and developing tax strategies (Tax Check-up)
  • Representing private clients with the tax authorities in connection with matters of tax and currency control law compliancе
  • Representing private clients with the tax authorities in case of receiving demands for provision of comments under automatic exchange of financial information

Services for Controlled Foreign Corporations (CFCs) in Russia

  • Assisting in establishing and servicing foreign companies and structures, such as trusts and foundations, together with our legal partners in foreign jurisdictions
  • Coordination of the process of transferring various types of assets into the established structures (securities, movable and immovable property in Russia and abroad, as well as other assets)
  • Preparing CFC tax reports
  • Preparing CFC financial statements in accordance with IFRS accounting standards; obtaining auditor’s report
  • Analysis of the feasibility of the transition to fixed profit taxation for CFCs, preparing applications for such a transition

M&A Transaction Support

  • Due diligence (financial, tax, legal)
  • Advising on transaction structuring, selecting optimal mechanisms to protect the buyer’s/seller’s interests
  • Providing legal support for negotiations and drafting agreements on the major terms of the transaction/negotiations (MOU, term sheet, etc.)
  • Drafting key transactional documents (share/interest purchase agreement, shareholders’ agreement/ participation agreement)
  • Preparing documents for taking necessary corporate actions to implement transactions
  • Legal advice in closing the transaction

Special Projects

  • Advising on new currency control regulation issues, such as evaluating legality of foreign account transactions, cross-border transfers and transactions with foreign securities and real estate
  • Assisting clients in cases of unjustified blocking of foreign assets
  • Structuring and supporting transactions to relocate foreign business to friendly jurisdictions, assisting in setting up foreign companies and structures in friendly jurisdictions
  • Providing support in opening corporate and personal accounts with banks located in friendly jurisdictions

Аmnesty of capital

  • Analysis of the Client’s Declaring Assets and Accounts within the Amnesty of Capital
  • Preparing and filing Special Declaration, related reporting documents enclosed to the Special Declaration, as well as other documents to ensure guarantees under the Capital Amnesty are applied
  • Preparing the «safeguard file»

Immigration and obtaining a foreign residence permit/citizenship

  • Advising on the best program to get a residence permit or citizenship in a foreign country, as well as supporting private clients in obtaining a residence permit/citizenship
  • Assisting private clients in the procedure of relinquishing Russian citizenship
  • Analyzing tax implications of changing Russia’s tax residency status, including comparative analysis of jurisdictions where tax residency may be obtained with a focus on special taxation regimes with beneficial tax treatment
  • Analyzing tax and currency control regulation consequences of losing Russian tax residency


  • Comprehensive support for managing and administering family wealth in terms of law, taxation, currency control regulation, and inheritance in Russia and abroad:
  • Assessing and monitoring compliance with the law in Russia and abroad
  • Coordination of cooperation with the client’s legal services providers
  • Resolving clients’ various issues and representing their interests with the Russian tax authorities, the Ministry of Internal Affairs authorities, courts and other state authorities

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