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Tax Risks Minimization: Status 2018, 11-12 October 2018


New transfer pricing legislation overview 
Anastasia Kostareva, Management Accounting and Budgeting Methodology Department Head


• Specifics for Transfer Pricing local and global documents preparation
• Transfer pricing draft bills overview
• Current court practice
Tax risks management practice in T Plus Group: Approaches, methods, tools, and implementation practices 
Kirill Tkachenko, Tax Policy Department Head, Tax Department

T Plus

• Tax risks sources. Sequence of actions for tax risks identification, allocation, evaluation, and digitalization
• Tax risks practical management tools (risk map, tax map, enforcement map): Setting up and using Integrating new tax control trends into risk map (matrix)
• What is check list? Filling up and using it at the company level
• Tax risks management: Stages and liabilities (who is responsible for what part)
• Risk decision making process: Organization and technology algorithm
Interactive with tax authorities outside tax audits - commissions, pre-audit analysis, and other tools 
Maria Olkhovikova, Tax Reporting Department Head

Inter RAO - Electricity Generation Management

• Is commission meetings attendance mandatory (VAT, Payroll, Debt, etc.)?
• Pre-audit analysis specifics
• Cross audit of counterparties
Corporate Tax Risk Management System efficiency assessment 
Dmitry Rybko, Taxation Department Head

Raiffeisen Bank

• Essence of corporate tax risks management efficiency
• Is there a way to assess tax management system efficiency?
• What efficiency assessment methods shall one choose?
• Organizing control over tax risk event
• Key success factors: Things to remember in the improvement process
Tax audits: Comprehensive approach to audits and ways to protect taxpayer's rights 
Sergey Lavrov, Tax Expertise Unit Head, Tax Department


• Basic steps to create efficient protection strategy during an audit
• Recommended tax pre-audit set of intercorporate preparation activities within
• Forming business relationship with the Tax Inspection during tax audit
• GR department role (Government relations) during tax audit
• Practical recommendations on tax audit procedures appeal
• Tax audit results dispute settlement
Company employees’ behaviour during interview in tax authority
Dmitry Kirillov, Attorney, Tax Practice Head


• Getting ready for interview
• Procedural tactics overview
• Interviewing several persons
• Lawyer participation 
Tax compliance as a way to reduce tax risks: Is it myth or real tool to ensure Company tax safety?
Dmitry Kirillov, Attorney, Tax Practice Head
Stanislav Gevorkov, Tax Department Head
MCB Capital
Alexander Yerasov, Tax Advisor

Bryan Cave Leighton Paisner (Russia)

• Is it really compliance?
• Modern tools for building a tax compliance system: From consultancy to ‘Veto’
• Choosing a contractor - separate department, accounting, outsourcing
• Tax compliance as the bas for internal control over taxis in the company
• Tax compliance manager - Does a company need the employee and what knowledge shall he/she have?
• Elaborating tax compliance control activities and management mechanisms to be integrated into current regulations and business processes
• Tax Compliance System efficiency indicators
• Training the personnel engaged into compliance procedure after tax compliance deployment
• Risk map, industry specifics
Property cadastral value for taxation purposes 
Maxim Gusev, Tax Disputes Department Head 


• Property acquisition and disposal during tax period
• Regional specifics, lists
• Legal precedents review
Using technology to help manage TP documentation globally
Luis Carrillo, Attorney, Tax Practice Head

Bureau van Dijk

Practical aspects of Company tax payments planning and optimization: Things to pay attention to
Stepan Lubavsky, Tax Planning and Control Department Head


• Company tax burden calculation and analysis
• Making Company tax liabilities forecasts (tax calendar)
• Interacting with consulting on taxation planning and optimization
Contractor’s reliability assessment as a taxpayer’s due diligence
Victor Sakharov, Deputy Chief Accountant for Tax Accounting


• Lack of due diligence as tax risk, history of occurrence
• Court approach to the taxpayers’ due diligence
• Tax authorities approach when auditing taxpayer’s contractors
• Company regulatory mechanisms to ensure due diligence
• Due diligence practical algorithm when selecting contractorsа
Tax aspects of blockchain technology in Ethereum platform 
Anna Romanova, Tax Planning and Analysis Department Head


• Crypto assets and regulation
• Smart contracts and application opportunities
• State registers
Article 54.1 of Russian Tax Code practical application
Vladimir Donchenko, Taxation Department Head

Renaissance Construction

• Reality or business purpose?
• Taxpayer and tax authorities proofing specifics
• Tax reconstruction
• Retroactivity 
Company management personal liability form tax default
Alexander Yerasov, Tax Advisor (head of the tax disputes resolution group, criminal law defence for tax crimes)
Rimma Malinskaya, Counsellor of dispute resolution practice (commercial disputes, international arbitration, bankruptcy)

Bryan Cave Leighton Paisner (Russia)

Tax default liability system
Criminal, administrative, and tax liability applicable to large enterprise top managers
Liable parties - who is in the risk area?
Why VAT refund and overpayment may pose danger
Why payments to foreign companies may be dangerous
Most turbulent areas and what operations are attacked in the first place
Management’s property liability for the corporate tax debts:
  • Developing practice of tax collection as fax crime compensation
  • Controlling persons subsidiary liability
  • Ground to hold accountable or exempt from liability
  • Nominee directors’ liability
Case study
Business protective activities - what shall you do now or what to start from?
Corporate tax risks management, Severstal 
Igor Hotkin, Senior Manager of the Tax Administration


• ‘Severstal” Tax Department structure
• Required tax risks management resources
• Different approaches to tax risks management system - what to do and what to automate
• Identifying transactions with significant tax risks.
• Tax risk digitization:
• Tax risks management stages - identification, significance assessment, reaction, and results analysis. 
• Risk control methods: When and what to outsource
• Tax risks management in the Tax Administration System
Practice of person with actual right to income concept application for international taxation purposes
Anastasia Smotritskaya, Chief Accountant

Artsana RUS (CHICCO)

• Foreign companies independence criteria
• Loans, royalties, and other ways of generating income from foreign companies
• Legal precedents review
• Current Federal Tax Service explanations on Actual Right to Income
Application practice of Russian Federal Tax Service methodological recommendations to identify intent
Anton Toroptsev, Tax Department Head


• Proving the coordination of actions
• Using operational investigation results
• Is there a point in proving due diligence?
Creating system for proper primary documents registration in tax accounting: What should be foreseen?
OlgaGolovina, Chief Accountant


• What can supervisory authorities pay attention to when reviewing primary documents
• Russian Constitutional Court decision on legality and economic validity of expendable documents
• Tax authorities requirements and arbitration practice
• Holding liable Chief Accountant for document storage regulations violations
Reorganizing business with minimal tax risks
Oleg Buryakov, Tax Department Head


• Tax liabilities succession of a reorganized enterprise
• Specifics of tax liabilities allocation between the organizations formed as a result of allocation
• Tax consequences of merger, separation, division by main taxes
• Merger specifics: Profitable company with unprofitable organizations
• Review of arbitration practice on tax disputes related to business reorganization
Creating an effective tax structure and tax planning in international holding companies
Marina Trofimova, Tax Department Head

Nordgold Management

• Creating an effective tax structure and tax planning in international holding companies
• Taxation of foreign holdings owning Russian capital
• Mistakes in optimizing foreign holding structures optimization: How to avoid them?
• Challenges related to Company non-residents economic activities in Russia
• Double taxation convention specifics
Organizing internal audit: Things to consider
Alexey Kaftannikov, Tax Department Head


• Tax audit organization main principles and order
• Financial, economical, and tax information processing specifics
• Duties and responsibilities distribution among the employees engaged in tax audit: Using respective procedures, regulations, and methods
• Taxpayers’ typical mistakes identified during tax audit
• Tax audit results report
Tax risks minimization when engaging non-residents
Ilya Linkov, Transfer Pricing Control Department Head, Tax Administration Division Head


• Taxation optimization when engaging non-residents on Double Tax Treaty
• Tax risks when engaging non-residents Positive and negative court practice analysis
• The tax risks minimization
“Tax on Google." VAT application practice to foreign companies digital services
Ilya Linkov, Transfer Pricing Control Department Head, Tax Administration Division Head


• Impact on Russian Global Businesses
• Calculation specifics
• Application practice
Representation expenses: personal and corporate interests balance 
Kirill Grinchenko, Tax Law Officer

Siberian Generation Company

• Representation expenses: classification principles
• Representation expenses registration
• Current court practice
• Representation expenses control methods
VAT legislation: recent changes, application experience, judicial practice
Nataliya Denisova, Tax Department Head


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