Tax

One of the well-known and leading Russian producer of longitudinal welded pipes

in ICC dispute against largest German heavy plate producer on collection of damages for more than EUR 150 mln arising from one of the major energy-related projects in Russia. ALRUD tax team provided tax opinion for the London arbitration court to support the Client in collecting part of the damages which included indirect taxes paid by the Client.

Multinational power company

on the tax incentives and special investment regimes available for foreign investors developing coal business in the Far East of Russia. ALRUD tax team supported the client in drafting a set of framework agreements on development of a coal deposit and negotiations with the Russian regional authorities on provision of tax and customs benefits and possibility to support the client during conclusion of an advanced transfer pricing agreement with the Russian tax authorities.

Multinational IT corporation

in litigation with two former employees of a Russian branch claiming that the client made excessive tax withholdings from their income by applying incorrect tax rates. ALRUD tax team developed an effective defense strategy and drafted procedural documents that allowed the client to prevail in the dispute. All claims of ex-employees were dismissed entirely.

The first-rate sovereign wealth fund

in relation to infrastructure projects, connected with building, or reconstruction, of highways in Russia. ALRUD tax team advised the client on the most effective tax structure for financing the projects, considering tax risks and tax implications arising from the provision of the low-rate loans and assignment of rights in respect to the existing loan debts.

One of the leading producer of the electronic technologies

on Russian aspects of the global purchase agreement, covering transfer of printer business over 50 jurisdictions and assisted with all tax matters related to completion of the asset transfer deal in Russia. ALRUD tax team drafted and negotiated the tax-related clauses of the agreements underlying the deal and advised the client on various tax matters connected with the deal (VAT, accounting matters, etc.).

One of the largest oil and gas companies

in the sale of its controlling stake in the company owning an oil service terminal and on the establishment of a JV with the major Russian oil company.

A leading energy company and oil refiner in Korea

on structuring of business activities in Russia and various tax aspects, including advising on tax risks connected with the Permanent Establishment issues, VAT, transfer pricing and currency control regulations. Additionally, ALRUD tax team drafted two requests to the Ministry of Finance and the Federal Tax Service of the Russian Federation in order to obtain their clarifications on disputable tax issues, in order to protect the client from future tax claims.

Russian manufacturer of innovative pharmaceutical products

in attracting investment from the direct investment fund operating in Russia. ALRUD tax team supported the client on group restructuring and provided recommendations re. the most effective tax structure for investments, including restructuring of existing debts with the lowest tax risks, advising on tax implications connected with thin capitalization and CFC rules.

A leading manufacturer of industrial machinery bearings and components

in assess of the tax risks and tax implications connected with creation of a Permanent Establishment (PE) in Russia. ALRUD analysed the structure of the client’s business in Russia and CIS, advised on steps required to reducing tax risks of the previous periods and elaborated a new structure of carrying out business in Russia and CIS, without PE risks for the client. As a result, the client decided to restructure its business in Russia.

Japanese international trade corporation

on establishment of a JV in Russia, including assessment of the tax risks related to the transfer of assets and further sale of JV, or its assets, VAT issues connected with in-kind contributions, etc.

The largest world-wide Internet-based retailer

with respect to the multinational project on launching an online marketplace. ALRUD tax team assessed the tax risks and provided advice on the tax considerations related to the client’s business structure, especially in the light of Russian VAT on electronic services, reviewed distribution and services agreements and suggested to amend the terms of use related to the marketplace.

Singaporean multinational commodity trading company, one of the largest oil and metals traders

on structuring and cross-border tax issues, related to the purchase of a stake in the large Russian energy business. This includes advising on the withholding tax on dividends and interest and capital gains issues, as well as application of the “beneficial owner” and the “look-through” concepts.

Main European subdivision of one of the largest investment banks in the world

on the tax issues related to its Funding Swaps and Repurchase Transactions, with the basis of Russian equities and derivatives. This included advising on the structuring of such transactions and application of the Principal Purpose Test (PPT) under the Multilateral Convention (MLI).

One of the largest coal mining and processing complexes in Kuzbass

during its on-site tax audit, related to the justification of transfer of the tax losses to future periods and accounting for the interest expenses on loans, issued for the development of the project.

Dynamic international pharmaceutical company

during the tax due diligence, which was aimed at checking two competing companies in the market, prior to their merger with our Client's subsidiary, and advised on the steps necessary to mitigate the resulting tax risks.

One of the first professional ice hockey leagues in the world

on structuring the broadcasting agreement for the online broadcasting of the hockey matches, with a leading technology company in Russia, including advising on issues related to the VAT on e-services and withholding tax on royalties.

Multinational power company with its head office in India

on the tax incentives and special investment regimes available for the foreign investors, developing a coal business in the Far East of Russia. ALRUD’s tax team supported our Client in drafting a set of framework agreements on the development of a coal deposit and negotiations with the Russian regional authorities, on the provision of tax and customs benefits and the possibility to support our Client, during the conclusion of an advanced transfer pricing agreement, with the Federal Tax Service of the Russian Federation.

The largest worldwide online retailer

during its multinational project on launching an online marketplace, for the sale of the software. ALRUD’s tax team assessed the tax implications and provided advice on structuring the agreements and Client’s business in Russia, from the tax law perspective.

Transnational oil and gas companies

during the sale of its controlling stake in the company, owning an oil service terminal and on the establishment of a JV with a major Russian oil company.

Major European investment fund

in relation to the tax investigation, which was aimed at investigating the distribution network of a Russian independent distributor. This included more than 50 companies from different regions of the Russian Federation. Our Client was interested in the tax investigation’s results to make a final decision on the acquisition of one of the leading European groups of companies,which produces hair care products.