| DAY 1: THURSDAY, 26 SEPTEMBER 2019 |
| Creating and efficient tax department and tax planning in holding companies |
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Aleksei Platunov, Head of tax planning
Simple
• Current international holding companies tax planning issues • Taxation of foreign holdings owning Russian capital • Mistakes in optimizing foreign holdings taxation: How to avoid them? |
| Creating efficient tax risk management system in the PUMA-RUS company |
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Viktoria Pigalskaya, CFO
PUMA
• Corporate tax risks: Nature and classification • Considering tax risks during management decision-making process. • Measures to reduce tax risks when developing corporate accounting policies • Tax Risk Management: Stages and Responsibilities • Inefficient tax risk management: Financial and legal implications |
| Actual issues of Art. 54.1, Tax Code application |
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Tatiana Gavrilenko, Tax manager
Fazer
• Reality or business purpose? • Features of evidence for taxpayers and tax authorities • Tax reconstruction • Retroactive law • Judicial practice development |
| Taxation of foreign companies VAT electronic services and tax consequences |
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Konstantin Solovyev, Tax manager for CIS countries
Nokia
• Tax registration of foreign organizations • "Old" rules application according to the Federal Tax Service Letters • Changes in services taxation with a place of sale outside the Russian Federation and the need to prepare for new tax control methods |
| Tax control over transactions with related parties |
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Madlen Tyves, Deputy head of tax
FESCO
• Canceling the control over TP for internal transactions between interdependent persons - what to be ready for • Judicial practice in disputes on unjustified tax benefit on transactions between related parties • Risk control system creation for transactions between related parties |
| Changes in corporate property taxation: Practice |
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Maria Olhovikova, Head of tax reporting
Inter RAO — Management of Electric Power Plants
• Exclusion of movable property from the taxation since 2019 • Classification of objects as movable or immovable • Regional specifics, lists • Judicial practice overview |
| Interaction with tax authorities outside tax audits - commissions, pre-audit analysis and other tools |
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Stepan Lubavskiy, Head of tax planning and control
Svyaznoy | Euroset
• Tax authorities commissions (for the legalization of the tax base, salary, for debt, etc.) • Pre-inspection analysis specifics • Counter inspection - interaction with tax authorities and counterparties |
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PANEL DISCUSSION: All about tax audits: Grounds and deadlines, result preparation, audit suspension and resumption, basis for reaudits |
| Anastasia Smotritskaya, Chief accountant Confederation of Danish Industry Aleksandr Erasov, Tax manager Bryan Cave Leighton Paisner
Dmitriy Kirillov, Head of tax dispute practice
MEF PKF
• The main steps required to form an effective protection strategy during the audit • Documents volume and request procedures for the tax authorities • Recommended set of preparatory measures within the company before the tax audit • Ways to protect the taxpayers’ rights during tax audits • Practical recommendations when streamlining communications with tax authorities representatives • Tax control measures analysis during tax audits • Disputes settlement arising from tax audit results •Tax audit results appealing procedure and when it is required |
| Separation of business: Risk minimization, additional taxation and court practice review |
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Oleg Buryakov, Head of tax
SMINEX
• Are company groups at risk? • Risks of "simplifiers" • Proving the business purpose of splitting • Current judicial practice |
| News of applying the concept of an entity with actual right to income (ARI) for international tax purposes |
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Marina Trofimova, Head of tax
Nordgold
• Independence criteria for foreign companies, the notion of substance • Loans, royalties and other methods of income generation from foreign companies • Judicial practice overview • Current explanations of the Federal Tax Service of Russia on ARI issues |
| Due diligence through the Article 54.1, Russian Tax Code prism: Changes |
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Maksim Zalazaev, Head of Legal
Inventive Retail Group
• Transformation of the lack of due diligence risk, taking into account art. 54.1 of the Tax Code |
| Tax authorities new approach to interaction with major taxpayers Interaction outside the tax audits scope |
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Viktor Saharov, Deputy chief accountant for tax
Airline UTair
• New accounting structure of the major taxpayers. What distinguishes the sectoral approach from regional one? • Is it necessary to conduct on-site inspections of the major taxpayers? • Monitoring without monitoring. Voluntary coercion to pay • Trust or verify. Is it possible to "negotiate" with the inspection? |
| DAY 2: FRIDAY, 27 SEPTEMBER 2019 |
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INTERACTIVE MASTER CLASS Ways to distinguish between tax evasion and legitimate tax optimization |
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Aleksandr Erasov, Tax manager
Bryan Cave Leighton Paisner
• Legal tax optimization, tax offense and tax crime - where is the line today? • Examples from practice • Trends in the unjustified tax benefit concept • The Plenum of the Armed Forces of the Russian Federation new resolution draft on tax crimes - the latest news • What operations do interest inspectors in the first place and how to protect yourself from claims? • The most common mistakes and how to avoid them • Questions and answers, analysis of specific situations from the audience |
| Tax reconstruction at tax audits: judicial and law enforcement practice |
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Ruslan Shvedkov, Financial director
BNS Group
• The history of tax reconstruction - from Resolution No. 53 to the latest clarification on 54.1 of the Tax Code • Tax reconstruction for VAT gaps and for recognition of contingent income tax expenses • Challenging cases of reconstruction (business fragmentation, loss transfer, trade fee, foreign element) • The practice of achieving adequate reconstruction in the inspection process |
| Tax Risk Management Practice for a Holding Company |
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Kirill Grinchenko, Head, tax and other obligatory payments
EVRAZ
• Consultation agreements and SEA agreements • Dividend payment • Property management • Interest-free bonds |
| Electronic document management systems use to prove the correct registration of relations with counterparties |
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Ludmila Golubeva, Chief accountant
Melon Fashion Group
• Choosing a counterparty, ETP (electronic trading platforms). • Counterparty card. • Contracts approval, agreement stages • Contract storage |
| Tax implications of registering foreign companies for VAT purposes in Russia |
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Arseniy Denisov, Tax manager for Russia and CIS
IBM
• Criteria and registration procedure • Implications for a foreign company • Implications for Russian buyers • Intra-group aspects of these changes |
| Tax risk minimization when doing business with non-residents |
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Ksenia Kashina, Tax advisor
Sakhalin Energy
• Taxation optimization when working with non-residents through the application of the DTT provisions • Tax risk when doing business with non-residents. Positive and negative judicial practice analysis • Minimization of such tax risks |
| Digital financial assets operations taxation - issues and possible approaches |
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Sergey Lavrov, Head of tax
Norilsk Nickel
• Status of digital financial assets bills • Applying Existing Tax Laws to Digital Financial Assets • Tax Authority Approach |
| Primary documents for tax accounting: Proper paperwork system basis |
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Vera Borisova, Tax Director
HP
• "Primary": What and how the regulatory authorities inspect • How to protect against problems in the primary documents preparation? • The courts approach to expenditure documents legality and economic feasibility issues • The boundaries of the accountant’s liability for documents storage rules violation |
| Approaches of tax authorities and courts to intragroup operationsApproaches of tax authorities and courts to intragroup operations |
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Natalia Zaytseva, Tax manager
AB InBev Efes
• Assignment of operations to intragroup • Operations reclassification • Specifics of proving the circumstances of intragroup operations |
| Tax control online - is your business interested? |
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Irina Zhdanova, Head of tax
IDGC of the North-West
• Tax monitoring review on the Tax Code of the Russian Federation • Tools development for a risk-based approach to tax audits • What could be the taxpayer's interest in the “background” tax control? • Assess the tax authorities abilities • Do you need a legislative initiative in this area? |
| Tax authorities digitization - How shall a taxpayer live? |
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Dmitriy Kirillov, Head of tax dispute practice
MEF PKF
• Tax authorities information systems • Digital document management • Model XML contract as the next step to digitalization • Information security as a way to prevent tax abuse |
| Current issues of transactions with intellectual property taxation |
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Ekaterina Kulikova, Tax advisor, financial controller • Identifying intellectual property objects in taxation: intellectual activity as a commodity, work, service, property rights. • Form or content: Tax authorities approaches to VAT benefits use control License agreement, author's order contract - how the form of the relationship affects the tax consequences; “Modification and adaptation” - problems of concepts in taxation • IT-companies "Insurance benefits" - Tax authorities inspection practices; emerging issues |
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