Retail and Wholesale

Case 1: Liquidation of Group’s Excessive Companies

Circumstances

Pending preparation for the introduction of rules regarding controlled foreign companies, the client has decided to reorganize the ownership structure including Cypriot companies and a BVI company.

Our Role

At the first stage we developed taxation models for the owners and companies included into the ownership structure of the group of the Russian companies, based on the calculations performed, the most optimal variant has been chosen.

During our work we have identified companies that are excessive for the current structure. For such companies, transactions have been arranged to transfer their assets and accounts receivable to the companies left in the operating scheme, and liquidation of such excessive companies has been commenced.

Besides, we assumed that there are potential risks due to possible interpretation of laws in such a manner that the companies' profit for 2014 might be recognized as income of controlling entities in 2015. In this regard, the transactions were structured so that to exclude occurrence of tax implications in the Russian Federation.