Services for Private Clients: our solutions

Advice and tax support to individuals applying tax laws regarding controlled foreign corporations (CFCs)

One of the key moments in the development of Russian tax law has been the introduction of new rules to “deoffshorize” the Russian economy and tax the profits of CFCs in Russia at the level of their ultimate beneficiaries who are also Russian tax residents.  Given the development and reforming dynamics of these new tax rules, owners of foreign assets have to constantly monitor changes to effectively manage newly emerging tax risks and ensure the stability of current and new ownership structures.

Our KPMG team consists of the leading advisers on matters related to applying the “deoffshorization” laws in practice. We have developed a systematic approach to implementing projects in this area to help our clients handle the full range of issues related to CFC ownership and manage their tax risks. In particular, we can help:

  • Run diagnostics on the ownership structure, which includes developing recommendations and practical solutions
  • Advise on the tax risk management techniques for the existing / new ownership structure
  • Plan and calculate a CFC’s taxable profit for Russian tax purposes
  • Plan and implement the transition to the new ownership structure
  • Make sure that all tax filings are made in a timely manner, and deal with the tax authorities on your behalf
  • Arrange effective processes to generate the needed documents to determine a CFC’s profit and use tax concessions (e.g. when the CFC is liquidated)

Advisory and assistance with Russian and international tax compliance

The past few years in the sphere of international taxation have been eventful, for taxpayers characterised by a shift to a new tax reality. The new approach to taxation and tax administration demands maximum transparency when conducting investment and entrepreneurial activities. Individuals have to pay close attention to tax risks and tax compliance in Russia and worldwide.

We advise our clients on all matters relating to international taxation, including the preparation and filing of statutory reporting with the tax authorities, and ensuring their compliance with tax law in Russia and worldwide. We offer an integrated approach to tax planning and managing tax risks, help prepare tax reporting, deal with the tax authorities, obtain certificates of tax residency, and provide officials with comments and explanations.

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Advisory on various Russian currency law issues and foreign account tax compliance

Over the past few years, the provisions in Russian currency laws have become a subject for discussion. On the one hand, these provisions have become milder, while on the other, government has tightened control over compliance.

The KPMG team in Russia helps our clients comply with Russian currency law, prepare reporting on foreign accounts, identify the potential risks which may be caused by currency transactions performed through foreign
accounts, and analyse income / asset ownership structures in terms of currency law, developing risk management recommendations with respect to the risks identified.

Tax and legal support for immigration / obtaining of residency in other countries

Rapid globalisation and toughening competition between jurisdictions has opened new opportunities for individuals to designate their place of residence and country of domicile. Programmes offering citizenship or residency permits in return for investment have become the most recent trend in the sphere of international
migration.

With extensive experience of obtaining foreign citizenship / residency, our KPMG team in Russia – in close cooperation with colleagues from foreign KPMG offices – helps our clients resolve all of the issues arising at each stage, including:

  • Choosing jurisdictions based on tax and legal risks and the conditions of and procedures for obtaining citizenship / residency
  • Developing and implementing investment strategies
  • Selecting real estate and administering it in the jurisdiction chosen
  • Legal support for real estate transactions
  • Obtaining passports, residence permits, visas, and other approvals and authorisations
  • Dealing with administrative authorities in the jurisdiction chosen, including the tax authorities, with respect to registration, obtaining official recommendations and tax certificates
  • Preparing and filing reporting

Property and investment planning and management

Against a background of frequently changing compliance issues, increased requirements for transparent ownership structures, and toughening control exercised by government authorities and international bodies, the need to protect, efficiently use and ensure the inheritance of assets increases. Individuals face the challenging task of managing long-term risks not only based on current legislation but also with regard to
potential changes in global asset management and protection trends.

Our team provides multi-family office asset and investment management and protection services to its private clients, including: 

  • Advising on marriage property and inheritance matters, as well as investment and charity activities
  • Running diagnostics on the stability of ownership structures, developing practical recommendations
  • Advising on structuring the ownership of assets via foreign holdings, funds, trusts, and other corporate and
    unincorporated entities from the perspective of various jurisdictions
  • Developing a new ownership structure and a step-by-step plan on how to transition to it
  • Tax and legal support for creating a new ownership structure and for purchase, use, and sale of property
  • Drafting marriage contracts and testaments
  • Intermediary services

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