DAY 1: THURSDAY, 11 OCTOBER 2018
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New transfer pricing legislation overview
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Anastasia Kostareva, Management Accounting and Budgeting Methodology Department Head
Mechel • Specifics for Transfer Pricing local and global documents preparation
• Transfer pricing draft bills overview
• Current court practice
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Tax risks management practice in T Plus Group: Approaches, methods, tools, and implementation practices
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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
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Interactive with tax authorities outside tax audits - commissions, pre-audit analysis, and other tools
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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
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Corporate Tax Risk Management System efficiency assessment
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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
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Tax audits: Comprehensive approach to audits and ways to protect taxpayer's rights
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Sergey Lavrov, Tax Expertise Unit Head, Tax Department
NorilskNickel • 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
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Company employees’ behaviour during interview in tax authority
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Dmitry Kirillov, Attorney, Tax Practice Head
A-PRO • Getting ready for interview
• Procedural tactics overview
• Interviewing several persons
• Lawyer participation
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Tax compliance as a way to reduce tax risks: Is it myth or real tool to ensure Company tax safety?
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Dmitry Kirillov, Attorney, Tax Practice Head
A-PRO
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
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Property cadastral value for taxation purposes
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Maxim Gusev, Tax Disputes Department Head
Rostelecom • Property acquisition and disposal during tax period
• Regional specifics, lists
• Legal precedents review
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Using technology to help manage TP documentation globally
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Luis Carrillo, Attorney, Tax Practice Head
Bureau van Dijk |
Practical aspects of Company tax payments planning and optimization: Things to pay attention to
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Stepan Lubavsky, Tax Planning and Control Department Head
Euroset • Company tax burden calculation and analysis
• Making Company tax liabilities forecasts (tax calendar)
• Interacting with consulting on taxation planning and optimization
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Contractor’s reliability assessment as a taxpayer’s due diligence
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Victor Sakharov, Deputy Chief Accountant for Tax Accounting
UTairAirline • 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
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Tax aspects of blockchain technology in Ethereum platform
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Anna Romanova, Tax Planning and Analysis Department Head
Polymetal • Crypto assets and regulation
• Smart contracts and application opportunities
• State registers
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Article 54.1 of Russian Tax Code practical application
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Vladimir Donchenko, Taxation Department Head
Renaissance Construction • Reality or business purpose?
• Taxpayer and tax authorities proofing specifics
• Tax reconstruction
• Retroactivity
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DAY 2: FRIDAY, 12 OCTOBER 2018
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INTERACTIVE MASTER CLASS
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Company management personal liability form tax default
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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:
Case study
Business protective activities - what shall you do now or what to start from?
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Corporate tax risks management, Severstal
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Igor Hotkin, Senior Manager of the Tax Administration
Severstal • ‘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
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Practice of person with actual right to income concept application for international taxation purposes
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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
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Application practice of Russian Federal Tax Service methodological recommendations to identify intent
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Anton Toroptsev, Tax Department Head
Teva • Proving the coordination of actions
• Using operational investigation results
• Is there a point in proving due diligence?
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Creating system for proper primary documents registration in tax accounting: What should be foreseen?
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OlgaGolovina, Chief Accountant
Selgros • 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
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Reorganizing business with minimal tax risks
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Oleg Buryakov, Tax Department Head
SMINEX • 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
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Creating an effective tax structure and tax planning in international holding companies
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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
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Organizing internal audit: Things to consider
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Alexey Kaftannikov, Tax Department Head
CHELPIPE • 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
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Tax risks minimization when engaging non-residents
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Ilya Linkov, Transfer Pricing Control Department Head, Tax Administration Division Head
Rostelecom • 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
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“Tax on Google." VAT application practice to foreign companies digital services
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Ilya Linkov, Transfer Pricing Control Department Head, Tax Administration Division Head
Rostelecom • Impact on Russian Global Businesses
• Calculation specifics
• Application practice
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Representation expenses: personal and corporate interests balance
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Kirill Grinchenko, Tax Law Officer
Siberian Generation Company • Representation expenses: classification principles
• Representation expenses registration
• Current court practice
• Representation expenses control methods
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VAT legislation: recent changes, application experience, judicial practice
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Nataliya Denisova, Tax Department Head
Sanofi |
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