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4:30 pm

Cyprus-Russia: the end of story or a new romance? A case study for business to prevent tax disputes.

October 4 @ 4:30 pm - 6:35 pm

Rustem Ahmetshin Senior Partner Pepeliaev Group Recent case law development on requalification of the intercompany payments into dividends distribution (case study) How loans are requalified into investments without application of thin cap rule (Continental Tyres case, Rusneft case) Challenging of the debt push down structures (Mondelez case) Requalification of intercompany services into profit distribution: what evidences are used by the...

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