Tax consulting

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Quality and customized tax solutions that fit your needs and budget

Our clients are personally served by specialists with many years of experience in advising on tax matters. Combining experience in audit, accounting, tax and legal support, we have knowledge of the best practices applied by companies and prefer to provide solutions rather than theory that is far from reality.

We offer the following tax services:

Corporate taxation: income tax, VAT, property tax, social contributions

We will answer all your questions regarding corporate taxes. Our team combines a high level of expertise with knowledge of local laws and that is why we can help you understand the tax rules that apply to both local and cross-border transactions (international taxation).

Transfer pricing

Transfer pricing – this is one of the most important tax issues faced not only by large international companies, but also by any organization that has cross-border operations. We offer quality and customized transfer pricing services that fit your budget.

Over the past 7 years, the Marillion team has successfully implemented more than 300 transfer pricing projects for international groups of companies in various industries, including representatives of the manufacturing sector, the consumer goods industry, pharmaceuticals, food and beverages, etc. .

Our team helps clients in the following areas:

  • Diagnosis of transfer pricing risks;
  • Development of internal policy on intra-group pricing of transactions;
  • Implementation of appropriate information flows necessary to comply with transfer pricing rules;
  • Preparation of transfer pricing documentation and transfer pricing notifications;
  • Advising foreign companies entering the Russian market on existing transfer pricing rules to ensure that the group's transfer pricing policy and approaches to its implementation are adapted from the very beginning as necessary to mitigate potential transfer pricing risks.

We use various information databases to obtain comparable data: SPARK, Ruslana, Amadeus, Orbis, Bloomberg, Royaltystat, etc.

What are the added benefits of preparing transfer pricing documentation?

Decisions and regulation of transfer pricing, in addition to eliminating the risks of non-compliance with legal requirements, can bring such benefits to the company as:

  • reduced effective tax rate;
  • optimization of intra-group cash flows;
  • reducing or even eliminating tax risks related to intra-group transactions.

Taxation of individuals

The Marillion team provides support at all stages of the individual taxation process, providing services such as the preparation and filing of a personal income tax (3-PIT) declaration, the preparation of payment instructions for the payment of PIT, tax reporting of individuals in relation to foreign companies, etc.

Wide range of services:

  • Preparation and submission of a 3-NDFL declaration
  • Checking tax notices and preparing payment instructions for the payment of personal income tax (as well as penalties and fines)
  • Submission of requests for certificates from the tax authorities (including certificate of no debt, certificate of tax residency, etc.)
  • Providing advice on individual taxation in Russia
  • Preparation and submission of a notice of opening/closing/change of account details with a bank outside the Russian Federation, as well as a cash flow statement on foreign accounts
  • Interaction with tax authorities in relation to property taxes of individuals (transport tax, land tax, property tax of individuals)

Tax reporting of individuals against foreign companies:

  • Preparing and filing a notice of participation in foreign organizations
  • Preparing and filing a Controlled Foreign Company (CFC) notice
  • CFC profit calculation

Tax audit: identification of tax risks and tax potential

  • as a preparatory stage for an on-site tax audit, during the audit we will detect tax risks and prepare recommendations for eliminating or reducing such risks, thus minimizing possible penalties;
  • if a company wants to reduce the tax burden and optimize tax payments to the budget of the Russian Federation, we will audit your company and prepare recommendations for reducing tax expenses in your particular situation, so you will understand the existing tax new potential in your company.

Tax Dispute Resolution

The practice of resolving tax disputes provides clients with comprehensive support on key issues of interaction with the tax authorities:

  • support during on-site and in-house tax audits, incl. inspections in connection with VAT claims for reimbursement, refunds of overpaid taxes, analysis of the legitimacy of requirements for the submission of documents and actions of the tax authority, advising on the preparation of responses to requirements and the most favorable submission of information and documentation to the tax authority, training employees for interrogations and accompaniment during interrogations;
  • pre-trial challenging of acts and decisions of tax authorities, including analysis of acts, assistance in collecting evidence, preparation of objections to acts, representation of interests when considering audit materials in tax authorities, preparation of appeals against decisions of tax authorities;
  • judicial challenging of the decisions of the tax authority in arbitration courts, including the preparation of an application to the court, other procedural documents necessary for conducting a court case, assistance in collecting evidence, representing interests in court.

Tax advice on mergers and acquisitions

M&A deals often involve risks and irregularities that need to be detected at an early stage. Our professionals will detect tax risks through tax due diligence, prepare recommendations to eliminate/mitigate such risks, develop a merger/acquisition strategy and future business structures that will be tax-efficient.

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