Deloitte CIS French Services Group
The Deloitte CIS French Services Group is a Moscow-based team of French nationals and French-speaking specialists dedicated to assisting French and French-speaking clients in expanding their businesses in Russia and the CIS.
The French Services Group comprises practitioners from the entire spectrum of industries and specializations, from auditors to tax analysts, consultants and lawyers, all of whom being experienced in regularly advising clients from France and French-speaking countries (Belgium, Luxembourg, Switzerland, Canada, Africa) and engaged in business matters in Russia and the CIS regions or in cross-border transactions.
Most of our team studied both in France and in Russia and are capable of providing a highly diversified and high-quality level of business support to ensure the international development of their French-speaking clients’ businesses.
If you would like to find out how we can assist your business expansion in Russia and the CIS, please do not hesitate to contact us.
We are pleased to present a summary of tax incentives offered in Moscow. This presentation will help investors identify key criteria for participation in the city’s tax reduction program.
Analysis of the Oriflame case, a very innovative decision in the fields of royalty payments and permanent establishment issues
The Moscow District Commercial Court issued a controversial decision on 11 June 2015, in which it ruled that expenses associated with the payment of royalties by a Russian company to a foreign affiliate under a sublicensing agreement were nondeductible for profit tax purposes. The commercial court affirmed the ruling of two lower courts and the position of the Russian tax authorities.
This article overviews the decision and makes some comments on the potential impact of the case for multinational companies charging royalties to Russian subsidiaries.
Over the last couple of years, the Russian legislature has been prolific in developing changes to tax legislation. Many of these changes became effective from 1 January 2015. One of the key developments has been related to the taxation of controlled foreign companies with the goal of creating an effective mechanism to prevent Russian business from misusing low tax jurisdictions and receiving unjustified tax benefits. Another innovation aimed at bringing the Russian tax system closer to the best global tax practices is the introduction of tax monitoring, which should allow for a transition to a "preventive" mechanism of tax control.
The French Desk took part in commenting on the Russian aspects of a major international asset-sale deal in the field of energy, involving a French group. The analysis focused on the potential Russian tax consequences of the sale of companies owning assets locally.
Deloitte advised a high-net-worth individual, a French tax resident, in restructuring his activities in order to address the new challenges of Russian and French tax law.
Deloitte’s French Desk won several engagements on the application of the beneficial ownership concept for Russian-sourced payment, involving analysis of payment structures and reviews of the required documentation.
Deloitte’s French Desk and the Transfer Pricing department teamed up to propose innovative solutions to a French group currently considering increasing its production in Russia to take advantage of the favorable ruble evolution while keeping a fair transfer pricing policy.
Deloitte’s French Desk advised a Russian high-net-worth individual regarding his personal individual income tax situation, in particular, his tax residency as regards the French and Russian rules.
Deloitte’s French Desk in Moscow successfully assisted a French logistics company operating in Russia in identifying and improving its financial situation regarding the Russian thin-capitalization rules. The consequences at the level of the French parent company, as well as the legal questions associated with the loan structure, were also covered.
The French Desk in Moscow successfully assisted a major Russian energy group in communicating with the French tax authorities and clarifying the individual income tax situation of its employees based in France.
Deloitte’s French Desk carried out a review and translated the internal rules of a French group into Russian to ensure their applicability at the level of the Russian subsidiary.
Deloitte’s French Desk, together with our Legal Department, took part in restructuring the Russian top management of a large French retail group.
One of our clients, an international French software group, recently entered a partial asset transfer in France during a carve-out operation. The transferred assets included shares in their Russian subsidiary. Deloitte’s assistance with all legal aspects of the transaction on the Russian side was requested.
Deloitte successfully provided consulting services to a French multinational group on issues arising during the conclusion of a cash-pooling agreement between the French parent company and its Russian subsidiary. In particular, tax, currency control and banking regulation issues were addressed.
Deloitte advised a Russian individual on the optimal structuring solution for the acquisition of a castle in the South of France from a tax and legal standpoint.