Practice

Tax and Tax Disputes

The tax practice combines advice on taxation matters and representation in disputes with the tax authorities.

We act for companies, business owners and investors in planning transactions, changing business structures and resolving tax disagreements.

The main areas of work include tax disputes, assessment of the tax consequences of transactions and reorganizations, tax planning and international taxation, including controlled foreign company matters. Advice covers the application of tax incentives and investment regimes; clients' interests are represented in pre-trial appeals and in court.

The legal position is formed on the basis of an analysis of the actual substance of the transactions, their business purposes and the supporting documents. The approaches of the tax authorities and case law are taken into account, as are the interrelation between the obligations of group companies and the possible consequences of the decisions under consideration for the business and its owners.

Services

Tax Audits and Disputes

Advice and Planning

CFCs and International Taxation

Tax Incentives and Investment Regimes

Documents and Consultations

Selected Experience

Division of a business

Tax consequences of dividing assets on exit from a partnership

Challenge

When the partnership came to an end, the assets were redistributed between the parties. A direct division of the assets would have had significant tax consequences for both parties.

What was done

The exit structure was worked through separately and reconfigured in the light of the legal characterization of each transaction and its tax consequences. The balance of the parties' interests was preserved in the process.

Foreign Trade Contracts

Tax and currency aspects of international sale contracts

Challenge

A Chinese company required a legal review of contracts for the international sale of goods between China and Russia.

What was done

Alongside the applicable law, the delivery terms (Incoterms) and the dispute resolution procedure, the currency and tax aspects of the contracts were analysed. The risks were identified and eliminated before signing.

Key Contacts

Deni Murdalov Partner, PhD (Law), LL.M.

Request a free consultation

Describe your matter and the circumstances in which it arose. The consultation establishes the possible structure of the work and the scope of legal support required.

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