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

04/10/2018 @ 4:30 pm - 6:35 pm

(Last Updated On: 18/09/2018)

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 tax authorities to prove deemed dividends distribution. How to protect companies’ position

Andrey Kirillov

Senior Associate

Pepeliaev Group

Foreign holding structures and investment companies under scrutiny in Russia

  • How to demonstrate to the Russian tax authorities and courts that CypCo is not a brass plate and conduit company? (case study)
  • What is «conduit nature of payments» from the Russian perspective?
  • What is “substance” from the Russian perspective?
  • Whether a holding or a treasury group company can ever be considered as a beneficial owner of income for the DTT purposes from the Russian perspective?
  • What is “defense file” and how shall it be prepared from the Russian perspective?

Maria Nicolaou



Restructuring considerations and transactional substance when doing business through Cyprus structures

  • Restructuring business structures that are under scrutiny
  • Tax and other considerations of operating business structures
  • Demonstrating substance in Cyprus from an operational and transactional perspective
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