International Tax

Services

International Tax

Deloitte's International Tax professionals offer services that help multinational companies, private clients, and their family offices manage change in a rapidly evolving global tax environment, bringing vision for the future and providing clarity and confidence to make informed decisions today.

Our service offerings

An integrated, flexible and sustainable tax strategy is a staple of any cross-border business. The growing attention to base erosion and profit shifting (BEPS) in Russia and abroad is a decision-making factor when structuring cross-border transactions and foreign investments. We develop and implement a wide range of turnkey solutions for managing effective tax rates and risks for multinational clients, including complex restructuring in multiple jurisdictions. Our services range from advisory on complex transactions and structures to “one-off” day-to-day issues. We also act as the first stop for potential investors wishing to gain a working perspective on the operating conditions, taxation, and investment climate of a foreign jurisdiction.
Our service offerings:
In the majority of our projects, we advise on:
  • legal structures
  • finance and treasury
  • intellectual property (IP)
  • supply chain.
Depending on our clients’ needs, we offer a full suite of international tax services, such as:
  • advisory on tax issues in Russia and abroad: from tax treatment of particular transactions and structures abroad to guidance on de-offshorisation and BEPS
  • tax diagnostics and strategic tax review of structures/models to identify potential risks and develop a tax strategy to meet the challenges of a changing tax landscape
  • interpretation and application of double tax treaties (DTTs) in light of the BEPS Multilateral Instrument (MLI), including limitations on benefits, the principal purpose test, additional criteria for passive income reliefs, taxation of indirect sale of real estate, and revised definition of a permanent establishment
  • preparation and review of documents from the tax perspective, including for intragroup operations
  • assistance with mandatory transparency requirements, including the disclosure of cross-border transactions in accordance with the EU’s Mandatory Disclosure Rules (DAC6), the OECD’s Common Reporting Standard (CRS), and FATCA
  • advice on international tax issues for private clients and their family offices as a part of Deloitte Private team
  • organisation of events, workshops, seminars, and conferences on international taxation.
  • Legal structures

    • Business expansion planning:
      • selection of investment strategy and business structure
      • advice on collective investment vehicles
        • relationship structuring
        • taxation of investors, including regulations on controlled foreign companies (CFCs)
        • taxation of passive income under the Russian Tax Code and DTTs, including the application of the look-through approach
    • Tax aspects of business restructuring:
      • reorganisations (mergers, acquisitions, split-offs), including cross-border reorganisations
      • cross-border tax and legal migration, including into Russian special administrative districts
      • liquidation of foreign companies
      • intragroup transfers of assets, including real estate
      • tax structuring of IPOs, Eurobonds, and private placements by Russian businesses
    • development or adjustment of the strategy on retained earnings and other reserves
    • tax planning, structuring and support with cross-border mergers, acquisitions, joint ventures, equity investments or divestitures (including transactions with real estate).
  • Finance and treasury

    • development or adjustment of strategies for intra-group financing for multinationals and effective allocation of funds in private structures, including at-source taxation, thin capitalisation rules and other interest deductibility limitations
    • advise on significant transactions:
      • financing of acquisitions
      • restructuring of intragroup debts
      • revision of existing debt obligations.
  • Intellectual Property

    • structuring IP ownership; selection of location of intangible assets that would be optimal from the economic and tax perspective
    • structuring international IP transactions; structuring of contractual relations, including intragroup arrangements
    • support during the transition to a target IP structure.
  • Supply chain

    • structuring of operating activities; selection of locations for group operations based on the economic and tax criteria
    • structuring of international transaction flows; design of contractual arrangements, including for intragroup operations
    • advice on Russian and international business taxes; analysis of permanent establishment risks.
Being well prepared for potential tax audits in Russia and abroad is one of the keystones of an integrated, flexible, and sustainable tax strategy. By examining and resolving potential controversies, we help multinational corporate groups and private clients manage risks at the stage of transaction/operations planning and reporting to mitigate disputes with the tax authorities.
Our service offerings:
  • developing defence files for potential tax disputes; providing recommendations on documentary evidence and evaluating litigation outcomes
  • discussing the client's position with the tax authorities on a “no-name” basis before filing tax returns or performing a transaction and obtaining written tax clarifications (e.g., tax rulings)
  • assisting clients with declaring assets as part of voluntary disclosure (capital amnesty) campaigns
  • communication with the tax authorities to clarify ambiguous legislative provisions and settle other tax administration issues
  • preparing responses to inquiries from the tax authorities
  • assisting with mutual agreement procedures (MAP)
  • international tax methodological support to Deloitte’s Tax Dispute Resolution group.
  • For multinational companies

    We advise clients on controversial issues relating to the taxation of passive income (dividends, interest, royalties, capital gains, etc.), payments for intra-group services, controlled foreign company (CFC) profits, permanent establishments, etc.

  • For private clients

    As a part of Deloitte Private team, we help develop, review and fine-tune tax strategies for transactions and operations of private clients and their family offices, assess if the clients are ready for the tax authorities to examine their foreign income, property, gift, inheritance, and other tax obligations and assist with the on-going tax litigations abroad.

In a global strive for financial transparency, compliance with international tax filing and disclosure requirements is becoming ever more challenging: as the scope of reportable and publicly available data expands, companies feel the need of additional tax-related technology and other resources to file returns and manage the growing administrative workload associated with intragroup transactions.
Our service offerings:
  • tax compliance on a regular basis:
    • disclosure of interest in foreign companies and structures; CFC-related disclosures and calculation of CFCs’ profit
    • reporting of potentially aggressive tax planning arrangements (in accordance with DAC6 – the EU’s Mandatory Disclosure Rules)
    • exchange of financial account information
      • FATCA reports based on the US IRS forms
      • filing reports to the Russian Federal Tax Service under the OECD’s Common Reporting Standard (CRS) and Chapter 20.1 of the Russian Tax Code (“Automatic Exchange of Financial Information with Foreign States (Territories)”).
  • ad-hoc tax compliance associated with:
    • establishment of foreign companies and structures
    • liquidation, corporate reorganisation, tax and legal migration of foreign companies and structures, including amendments to or removal from national registers, tax de-registration, filing of income tax returns after tax migration to another jurisdiction
    • tax registration of permanent establishments (PEs) abroad
    • assistance to claim double tax treaty (DTT) benefits, including confirmation of beneficial ownership
    • claiming local tax benefits
    • assistance to claim foreign tax refunds/credits
    • declaring assets as part of voluntary disclosure (capital amnesty) campaigns.
  • assistance in developing methodological guidelines for tax treatment of cross-border transactions
  • development of a workflow reliably reflecting the economic substance of cross-border transactions/entities and information on taxable items
  • technology solutions to automate tax compliance:
    • KIMOgraph – a solution for automated Controlled Foreign Companies (CFC) reporting
    • CRS Classifier tool to determine the status of a legal entity or unincorporated structures for the OECD’s Common Reporting Standard (CRS) purposes
  • advising, coordinating, and supporting the clients’ tax and compliance teams with tax compliance, including:
    • analysis of the list of documents required by the Russian and foreign tax regulators based on the client’s profile
    • assessment of historical and potential risks and implications of non-filing or late filing
    • development of an information disclosure strategy to ensure it is complete and reliable while minimising the risks.

About us

Deloitte CIS International Tax is a part of the firm’s new Global International Tax Service Line, which, together with Transfer Pricing and M&A, constitutes Global Business Tax Advisory Services (BTAS), providing globally coordinated and consistent advisory services to clients.

With a network of more than 3,500 professionals around the globe and a consistent approach to international tax services coordinated through a single centre, we deliver fully integrated services tailored to specific market segments and needs of each client.

As complex projects often require cross-functional competencies (audit, financial advisory, consulting, etc.), including from foreign member firms of Deloitte Touche Tohmatsu Limited and third-party service providers, we act as a single point of contact and centre of expertise.

We work closely with other T&L teams, including Tax Dispute Resolution, Business Process Solutions (BPS), Technology and Processes in Tax and Accounting (TPTA), Transfer Pricing, Global Employer Services, and Deloitte Private.

Deloitte’s International Tax specialists take active part in improving the national tax framework as members of expert boards established by Russia’s legislative and executive authorities.

We constantly inform our clients and business communities of the most important changes and developments in international taxation.

Key contacts

Elena Solovyova

Elena Solovyova

Partner, International Tax

Over her 20-year professional career Elena has gained extensive practical experience in Russian and international taxation providing advice to large local and foreign companies on tax planning and tax... More

Oleg Troshin

Oleg Troshin

Director

Oleg specialises in advising Russian and multinational enterprises on the tax implications of cross-border transactions, cash repatriation strategies, development of tax-efficient holding, finance, li... More

Yulia Krylova

Yulia Krylova

Director, Tax & Legal

Over 15 years with Deloitte, Yulia has gained significant experience in tax consulting, providing services to Russian and international customers with a focus on property taxation and international ta... More