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Tax Risks Minimization: Status 2019, October 2019

Creating and efficient tax department and tax planning in holding companies
Aleksei Platunov, Head of tax planning

• 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
Viktoria Pigalskaya, CFO

• 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
Tatiana Gavrilenko, Tax manager

• 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
Konstantin Solovyev, Tax manager for CIS countries

• 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
Madlen Tyves, Deputy head of tax

• 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
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
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


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

• 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
Oleg Buryakov, Head of tax

• 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
Marina Trofimova, Head of tax

• 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
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
• Who is ‘bad’ counterpart?
• What do we want to learn about the counterparty and what can we do?
• How to protect your business from counterparty’s unknown tax risks
• How to demonstrate adequate due diligence when choosing a counterparty?

Tax authorities new approach to interaction with major taxpayers Interaction outside the tax audits scope
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?


Ways to distinguish between tax evasion and legitimate tax optimization

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
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
Kirill Grinchenko, Head, tax and other obligatory payments

• 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
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
Arseniy Denisov, Tax manager for Russia and CIS

• 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
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
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
Vera Borisova, Tax Director

• "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
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?
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?
Dmitriy Kirillov, Head of tax dispute practice

• 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

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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