| ???????????????? ???????????????? ???????????????????? ?????????????????????????The demand for tax optimization will always be? ???????????????????? ????????????????????????Natalia Kuznetsova, a partner at PwC in Russia ???????????????? ???????????????? ???????????????? ???????????? |
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about trends in the use of Russian and international companies in offshore jurisdictions, tax optimization, ?b? says Natalia Kuznetsova, a partner of the Russian office of PricewaterhouseCoopers.
? Do you feel an effective tactic of the Ministry of Finance, who refused any contact with wild-type offshores British Virgin Islands (BVI) or the Bahamas and chose the path of pressure on those with whom you can negotiate ? Cyprus, Switzerland, etc.?
? Yes, now, Russia has no information exchange agreements with offshore companies. As I understand it, this was the position of the Ministry of Finance, to negotiate the exchange of information with the countries of concluding the agreement with the Russian Federation for the avoidance of double taxation. However, the recent ?Guidelines for tax policy,? aims to sign more and separate agreements on the exchange of information, including offshore jurisdictions such as BVI or Bahamas. So, the concept seems to be changing: the Ministry of Finance recognized that the effective interaction on many international tax issues, including the law on transfer pricing, we need mechanisms for obtaining information.
? offshore companies with no success without struggle all the strengths of the country, including the United States. Can we say that the international sector, tax optimization as business contracts, yields to this pressure?
? not so much compressed as transformed. Tax planning as such is not going anywhere, but the mechanisms used are becoming more complex. International Tax Consultants are primarily orient clients to the fact that they should be the level of presence in the jurisdiction that they use for tax planning, adequate carried out through this function. Because all of the attention of tax authorities focus just on that. Through the mechanisms of control of transfer pricing, through the need to confirm the presence of business purpose of transactions, they are trying to limit any interaction with the offshore companies.
? Exotic offshore companies are losing market share?
? It?s happening, but slowly. Many entrepreneurs have come to the need for greater transparency, greater reliability of structures to build a business. And someone decides to abandon the BVI in favor of something more reliable, say Luxembourg. Yes, it will not be zero, and about six percent of the tax, for example, in respect of income from intellectual property, but such a structure would be more resistant to questions from the Russian tax authorities.
? Demand for optimizing somehow changed?
? It always will be. Line up the intra-flows in order to optimize the tax benefits ? the task of any management company. Our international partners have noted a curious trend. 15 years ago all the tax planning was based mainly around funding. For example, companies from the U.S., where income tax is 35%, to pay interest in a jurisdiction with low tax rate. These schemes are easy to implement. But at the beginning of the two thousandth tax authorities around the world are these simple structures to attack. It was necessary to transform the model to create a real level of presence abroad. Everything started to create parent companies in Switzerland and Luxembourg (where operating income subject to tax at lower rates), taking back staff and operations. Then the crisis came in 2008 ? many have realized that the cost of the real presence of very high, and returned to the simple schemes. While the risks of their challenge in comparison with previous models increased. I think it will take time, the economy is stabilizing, and everything will return to a serious perelopachivaniyu business models.
? Russian business in this trend?
? Our business is using a foreign structure, trying to really create a presence abroad. Aircraft recently in Cyprus, flying is not complete because people are fleeing from the deposits of Cypriot banks to pull out, but because there really is such a presence is established and maintained by the operation.
? Ministry of Finance in the ?Guidelines? promises to introduce taxation of undistributed earnings of foreign-controlled companies. In practice, this can be done?
? Yes, absolutely. The U.S., UK, Germany, France, Denmark, such legislation exists. It really allows you to impose on undistributed profits of subsidiaries of the holding level. However, in the UK is faced with the fact that British holdings were to leave the country because the rules did not allow businesses to breathe. So I had to change the law: tax planning abroad was considered possible, provided that in the UK holding company pays all the required taxes. The government realized that the fight against tax evasion should not stop the international expansion. It is important for the development of Russian legislation and this was taken into account international experience.
Interviewed by VadimVisloguzov
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