CFC Tax Law Support | KPMG | RU
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CFC Tax Law Support

CFC Tax Law Support

Consulting and tax support for private clients to comply with CFC legislation

Consulting and tax support for private clients to comply with CFC legislation

Advice and tax support to individuals applying tax laws regarding controlled foreign corporations (CFCs).

One of the key moments in the development of Russian tax law has been the introduction of new rules to “deoffshorize” the Russian economy and tax the profits of CFCs in Russia at the level of their ultimate beneficiaries who are also Russian tax residents.  Given the development and reforming dynamics of these new tax rules, owners of foreign assets have to constantly monitor changes to effectively manage newly emerging tax risks and ensure the stability of current and new ownership structures.

Our KPMG team consists of the leading advisers on matters related to applying the “deoffshorization” laws in practice. We have developed a systematic approach to implementing projects in this area to help our clients handle the full range of issues related to CFC ownership and manage their tax risks. In particular, we can help:

  • Run diagnostics on the ownership structure, which includes developing recommendations and practical solutions
  • Advise on the tax risk management techniques for the existing / new ownership structure
  • Plan and calculate a CFC’s taxable profit for Russian tax purposes
  • Plan and implement the transition to the new ownership structure
  • Make sure that all tax filings are made in a timely manner, and deal with the tax authorities on your behalf
  • Arrange effective processes to generate the needed documents to determine a CFC’s profit and use tax concessions (e.g. when the CFC is liquidated)

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