Indirect Tax

Services

Indirect Tax

Why Deloitte?

  • Our team brings together practitioners with a long record of excellence and strong expertise in advising global and Russian clients across industries on indirect tax and customs regulation.
  • Deloitte CIS is a member of the Association of European Businesses, the Franco-Russian Chamber of Commerce and Industry, and the American Chamber of Commerce in Russia; we actively participate in discussions on the most important and pressing regulatory issues.
  • The International Tax Review (ITR) Indirect Tax Leaders guide recognises Deloitte CIS professionals among the leading indirect tax advisers.
  • Deloitte CIS was named the European Tax Firm of the Year 2020 by the ITR's European Tax Awards, in particular owing to the projects involving the Indirect Tax & Customs team.

Our services

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  • In terms of VAT on digital services (the ‘Google tax’), we will

    • analyse the services provided by foreign suppliers to determine if they can be classified as digital services for VAT purposes and develop appropriate risk mitigation solutions
    • review contracts and supporting documents for necessary changes
    • examine corporate accounting systems for compliance with the Russian legislation on VAT on digital services
    • advise you on matters associated with VAT registration of foreign digital service suppliers, file VAT returns for digital services, and prepare registers of transactions
    • assist foreign suppliers of digital services with responding to tax inquiries
    • support your organisation during tax audits
    • develop optimal low-risk VAT strategies in case of regulatory gaps.
  • In terms of VAT treatment of transactions with foreign counterparties, we will

    • determine the place of supply of work/services for VAT purposes by:
      • interviewing representatives of service recipients/suppliers
      • analysing paperwork
      • studying judicial practice relating to VAT treatment of similar services
    • advise on setting up business processes to maximise VAT efficiency
    • provide guidance on amending paperwork to ensure that work/services qualify for being treated as supplied outside Russia
    • defend your VAT approach in and out of court.
  • To enhance your company’s VAT efficiency, we will

    do an all-round review of its business lines and identify opportunities to use a reduced or zero VAT rate, seek exemptions, reclaim VAT, and utilise other indirect tax savings options.

    To help you apply a 10-percent VAT rate or VAT exemption for certain goods, we will

    • analyse applicability of lower VAT rate/exemption
    • prepare recommendations regarding documentary evidence for sales transactions on which reduced VAT rate/exemption will be applied
    • prepare/enhance documentary evidence for the supplies regarding which 10-percent VAT rate or VAT exemption have been or will be applied
    • analyse court opinions in disputes over lower VAT rate application for food products supply in Russia
    • defend the reduced VAT rate and VAT exemption application in and out of court
    • assist with building vendor management models enabling to maximise VAT efficiency.

    To help you claim VAT exemptions for particular goods or services, we will

    • assess the VAT exemption potential by
      • interviewing representatives of service recipients/suppliers
      • analysing paperwork
      • analysing court opinions in disputes over VAT exemption application
    • prepare/enhance documentary evidence for the services on which VAT exemptions have been or will be claimed
    • defend VAT exemption claims in and out of court.

    To help you reclaim input VAT, we will

    • review, prepare or enhance paperwork to verify eligibility for recovery of input VAT and VAT paid as a tax agent or upon import of goods to Russia
    • analyse your company’s operations for additional VAT recovery opportunities
    • provide support during desk and field tax audits and represent you in VAT recovery disputes in or out of court
    • in connection with Federal Law No. 63-FZ, which set new input VAT recovery rules, starting from 1 July 2019, we will:
    • determine the place of supply of work/services and match them against operations listed in Article 149 of the Russian Tax Code
    • support your organisation during desk audits (which may become more frequent)
    • represent you in disputes over the applicability of Federal Law 63-FZ.
  • In terms of VAT treatment of movement of goods across and outside EAEU, we will

    • analyse VAT regulations and opportunities for applying lower VAT rates/exemptions on import of goods into Russia
    • analyse technical documentation for goods and determine the classification codes under the EAEU Commodity Nomenclature for Foreign Economic Activity to justify the claimed 10-percent VAT rate or VAT exemption
    • assist with preparing paperwork for requesting advance classification of goods to verify eligibility for the 10-percent VAT rate or VAT exemption for imports into Russia
    • review the existing paperwork and recommend improvements to claim the 10-percent VAT rate or VAT exemption for imports into Russia
    • analyse procedure of zero-rated VAT confirmation and prepare paperwork improvement recommendations for exports of goods, including to the EAEU
    • analyse VAT refund/recovery procedure in case of exports of goods, including to the EAEU
    • analyse tax implications (including VAT) arising from the traceability of labelled goods by the tax authorities
    • analyse processes for reporting VAT data when entering information on the import of goods subject to mandatory labelling and their further distribution into the track and trace system.
  • In terms of VAT on transportation services, we will

    • determine the place of supply of transportation and related work/services for VAT purposes by:
      • analysing paperwork
      • analysing precedents of VAT treatment of similar services in court practice.
    • review your organisation’s eligibility for zero-rated VAT on services
    • defend your approach to service VAT classification and VAT zero rate application in and out of court
    • develop recommendations on paperwork improvement to confirm that the place of supply of work/services is outside Russia or their eligibility for zero VAT rate
    • assist with designing a VAT-efficient vendor management strategy from scratch
    • advise on setting up business processes to maximise VAT efficiency
  • In terms of separate VAT accounting, we will

    • review/develop guidelines for calculating VAT pro rata to revenue, including
      • analysing issues relating to valuation of sold goods (works, services) or rights
      • analysing income for pro-rata revenue VAT calculation purposes
    • review/develop a five-percent threshold calculation methodology, including
      • the allocation of costs to VATable, non-VATable, and mixed-type operations
      • analysis of costs for the five-percent threshold purposes
    • develop/improve separate VAT accounting policy and required tax registries, taking into account the latest changes in VAT rules, judicial practice, and regulatory clarifications.
  • VAT in foreign jurisdictions

    Presence in more than 150 countries enables Deloitte to leverage its network of resources and provide integrated international solutions to:

    • analyse/develop cross-border transactions or production localisation strategies to optimise the tax burden; analyse indirect tax exposure from the Russian and foreign indirect tax regulations perspective
    • analyse and support cross-border transactions within the EAEU, taking into account the EAEU's customs regulations and national indirect tax regulations of member states
    • design/improve cross-border transactions’ paperwork to ensure compliance with the Russian and foreign indirect tax regulations and minimise indirect tax exposure.
  • In terms of unregulated VAT issues, we will

    • review the current legislation, judicial practice, and regulatory opinions on disputed VAT issues to develop an optimal solution and mitigate the exposure driven by uncertainty
    • prepare requests for clarifications to the Russian tax authorities to minimise potential risks
    • develop tax amendment proposals and an explanatory note on the basis of the global and Russian practices, if you are interested in having the disputed issue legislated
    • support in liaise with the authorities as the initiative is being considered.
  • In terms of excise tax, we will

    • advise you on an array of issues, such as
      • transactions in excisable goods in Russia
      • import of excisable goods into Russia
      • movement of excisable goods across the EAEU customs border
      • sale of excisable goods outside Russia
    • analyse the excise tax exemption potential, including by review your organisation’s operations
    • identify the available deductions to decrease the excise tax burden and review your company’s operations to maximise the deduction potential
    • analyse the existing import and export customs procedures to optimise the excise tax burden
    • analyse cross-border transactions to optimise the excise tax burden from the national excise rules’ perspective
    • review current laws, judicial practice, and opinions of the regulatory authorities on disputable excise tax-related issues to develop an optimal solution and minimise the exposure arising from legislative gaps
    • support you during desk and field tax audits and represent your interests in excise tax-related disputes in or out of court.

Key contacts

Tamara Arkhangelskaya

Tamara Arkhangelskaya

Partner

Tamara is a Tax Partner leading Deloitte Russia Indirect Tax team of 20 experts. Tamara has over 15 years of experience in advising a broad range of Russian and multinational businesses on complexitie... More