Practice

Tax planning

We build a business’s tax strategy for years ahead, before decisions are taken and the structure is fixed, rather than analysing events that have already happened.

Service

What the service includes

The difference between tax advice on a specific transaction and tax planning lies in the horizon. Planning concerns not one operation but how the business as a whole will pay tax over the next several years: at its current scale, as it grows, and in the event of a sale or a handover to the next generation.

We review the current structure of the business, assess the tax burden under different scenarios and propose an action plan, from the choice of tax regime to the organisation of intra-group settlements. The line between lawful optimisation and aggressive tax planning that attracts the attention of the Federal Tax Service is a fine one, and we are always on the side of the former.

We also advise on the tax aspects of passing a business to the next generation or to a partner. This is a moment that is often overlooked until the need for a transfer actually arises, although the right tax structure is put in place in advance, not at the last minute.

What the service includes:

A tax strategy for several years ahead Choosing and changing the tax regime Optimisation of intra-group settlements Planning as the business scales Tax aspects of handing a business over to a successor
Clients

Who it is for

The situations clients most often bring to us on this topic.

A growing business that is outgrowing its current tax regime A group of companies with intra-group settlements that have not been reviewed for a long time An owner planning to hand the business over to a successor or partner A company that wants to understand the tax consequences of scaling up in advance
Service

How we work

A fixed fee and a clear plan of action, agreed before work begins. The timeframes below are indicative and depend on the complexity of the case.

I

Analysis of the current structure

We study how the business currently pays tax and compare it with what the structure could look like under reasonable optimisation. Timeframe: 1-2 weeks.

II

Scenario modelling

We calculate the tax burden under several development options: growth in turnover, a change of regime, a change in the group structure. Timeframe: 2-3 weeks.

III

Action plan

We prepare a written plan with specific steps and deadlines, not abstract recommendations. Timeframe: 1 week.

IV

Implementation support

We help carry out the plan and adjust it as legislation or the business changes. Timeframe: on request.

Documents

What you will need at the start

We confirm the exact list for your situation at the consultation. This is a guide so that you arrive at the first meeting prepared.

Current financial and tax reporting The structure of the group of companies, if there is one Information on the business’s development plans for the coming years Data on intra-group operations and settlements
Practice

Key figures

Experience in this practice area specifically, not in practice as a whole.

1-2 years recommended cycle for reviewing the strategy Even if the business does not change, legislation and Federal Tax Service practice change quickly enough to justify checking the structure regularly.
5 related areas of tax practice Planning rarely exists in isolation from disputes with the Federal Tax Service, defence in audits and subsidiary liability.
2 planning horizons Short-term (the current tax period) and strategic (the structure of the business for years ahead). We work with both.
RUB 120 million claim rejected in a related case From our practice of defending a director against tax debts. It shows what happens when there is no planning at the outset.
RUB 34 million additional assessment overturned in a related case The result of challenging an audit, although proper planning reduces the likelihood of the assessment in the first place.
27 years of practice We have worked in tax law and business advisory since 1999.
Practice

Common mistakes

A structure with no genuine business purpose. A scheme built solely to cut tax, with no other economic rationale, is the first thing the Federal Tax Service looks at in an audit and the first ground for recharacterising transactions.

One-off planning with no periodic review. A structure built five years ago for the legislation of the time may create risks today. Tax planning requires regular checking against current requirements.

Planning at the level of a single transaction only. Optimising one operation without regard to the business as a whole can sometimes create risks elsewhere. Decisions need to be assessed together, not in isolation.

Result

What you get

A written plan with specific steps. Not abstract recommendations but a workable plan of action, with the reasoning behind each step.

A clear tax burden for years ahead. The owner understands how today’s decisions will affect tax under different scenarios for the business.

Lower risk of additional assessments. A structure built with a genuine business purpose is considerably more resilient to recharacterisation in an audit.

Readiness to scale or hand over the business. The tax aspects of growth or of passing the business to a successor are thought through in advance, not dealt with after the event.

FAQ

Frequently asked questions

How does tax planning differ from tax consulting on a transaction?+

Transaction consulting answers a question about a specific operation here and now, whereas planning builds a business strategy for years ahead. The two differ in horizon and depth, although they sometimes go hand in hand.

Where is the line between lawful optimisation and a risky scheme?+

The line is whether each step has a genuine business purpose beyond the tax saving. If a structure is built solely to reduce tax and serves no other purpose, the risk of recharacterisation by the Federal Tax Service is high, and we always say so frankly at the planning stage.

Does the tax strategy need reviewing if the business is not changing?+

Yes. Even if the business stays the same, legislation and Federal Tax Service practice change, so it makes sense to check the current structure against up-to-date requirements every 1-2 years.

Is tax planning suitable for a small business, or only for large companies?+

The principles apply at any scale, but the economic benefit of in-depth planning becomes more noticeable as turnover grows. For a small business, a one-off consultation on choosing a tax regime is often enough.

Do you guarantee that the structure will not raise questions with the Federal Tax Service?+

Nobody can give absolute guarantees. But a structure with a genuine business purpose and proper documentation significantly reduces the risks and strengthens the company’s position in the event of an audit.

Do you provide tax planning for individuals, not only for businesses?+

Yes. We separately advise owners on personal tax residency and the structuring of personal assets, including those with an international element.