Analysis of customs risks in a new model

Client Large manufacturer of consumer goods Background Supply of goods by a foreign parent company to a Russian subsidiary are controlled for transfer pricing that requires reaching a certain level of prices / margins. Historically the company used a number of instruments to achieve the targets, but after 2022 they no longer meet the group’s objectives. As a result, the group was considering other options to target prices / margins. Objectives To analyze consequences of different approaches to target margin of a Russian company by changing customs value of imported goods Results We delivered the following results to the client: Described consequences of different approaches to change customs value; Provided recommendations on possible alternatives to achieve the objectives.

Страница изменена: September 11, 2024

Путь: Главная > Кейс > Analysis of customs risks in a new model

An in-depth analysis of restructuring transactions

Client A large timber company Background At the beginning of 2022, many Russian companies faced an urgent need to change financing, ownership and operational structure of the business. At the same time, large number of changes, stakeholders and urgency in some resulted in inconsistent documents creating tax and legal risks. Objectives Legal and tax analysis of transactions, assessment of the level and amount of risks, advice on risk mitigation. Results Our first objective was to obtain a full set of documents prepared in support of the transactions, identify the documents submitted to authorities, and those missing for a proper compliance. Then we analyzed the transactions for tax and legal risks, determined the amount of risk. Finally, we advised on options to mitigate the risks. We delivered the following results to the client: Gathered a full set of documents to see the big picture; Identified the missing documents and prepated recommendations for their preparation; Identified tax and legal risks and provided recommendations to mitigate them.

Страница изменена: September 11, 2024

Путь: Главная > Кейс > An in-depth analysis of restructuring transactions

Development of a TP methodology for a timber company

Client One of the Russia’s largest timber companies Background Historically, the group has not dedicated sufficient resources to transfer pricing. The group focused on its current financial needs and determined the prices in transactions based mostly on these needs. As part of the restructuring, the group identified anomalies in the amounts of receivables and price fluctuations in the transactions. Objectives Analysys of the group’s value chain and nature of the transactions. Development of pricing methodology, preparation of TP documentation. Results We analysed the value chain of the group’s Russian and foreign segment, documented current price setting procedure and developed a procedure that takes into account organizational constraints of the group and market practice. Then we performed a transfer pricing analysis and prepared a local file transfer pricing documentation. The Russian local file was synchronized with the foreign local file. We delivered the following results to the client: Prepared a transfer pricing reporting: local file and a MNC notification; Documented current and developed a new price setting procedure that takes into account the market practice and organizational specifics of the group; Determined amount and level of risks and developed a strategy to mitigate them.

Страница изменена: September 11, 2024

Путь: Главная > Кейс > Development of a TP methodology for a timber company

Benchmarking for 20 jurisdictions for an IT company

Client A large software developer, operating in more than 20 jurisdictions. Background The Group operates in more than 20 jurisdictions that require a certain level of TP compliance. The Group prepares TP reports with a help of external advisors, however, the approach in the prepared documents is inconsistent and sometimes results in a duplication of work. Another concern was the cost of services, which adversely affects KPIs of the tax team. Objectives The objective was to analyze the TP requirements in the countries where the Group operates, improve the depth of analysis, identify overlapping legal requirements and optimize costs. Results We analyzed the TP legislation in the Groups’ jurisdictions and verified the results with the tax authorities of the respective countries. Further, we developed a template that eliminates inconsistencies in the analysis of similar transactions and reducing the cost of the analysis. We also was provided guidance regarding the scope and depth of the analysis, taking into account the nature and volume of the transactions, and the level of risks in the respective jurisdiction. Finally, we provided an advice on the pricing of transactions between Group companies to optimise the tax burden. We delivered the following results to the client: Eliminated inconsistencies in the TP reporting of countries with similar requirements and transactions; Developed a uniform approach to TP reporting; Provided advice on low-risk transactions; Descreased the costs and time cost by more than 30%.

Страница изменена: September 11, 2024

Путь: Главная > Кейс > Benchmarking for 20 jurisdictions for an IT company

Mitigation of TP risks for an agriculture company

Client A large vertically integrated agricultural groups of companies Background The transfer pricing was not one of the questions taken into account in the pricing of transactions within the Group. The sales sales and treasury teams handled the pricing and this sometimes resulted in significant debtor and unsystematic pricing of transactions between the companies. The group submitted the TP notification, but never prepared a transfer pricing documentation, never prepared an in-depth analysis of prices in transactions between Group companies. The priorities changes after the new TP law passed the parlament and became effective. Objectives Analyze the Group’s structure and value chain, determine the functional profile of the Group’s companies, determine the pricing method, develop a policy for prices setting and managing the transfer pricing process in the Group’s transactions, take into account current market practices. Results We analysed the value chain and functional profile of the companies. Performed an analysis of available sources of information on prices within the group, resulting in a decision to use the comparable uncontrolled price method and the comparable profitability method. Further, we determined the amount of transfer pricing risks, risks associated with the process of price management and contracts between companies and provided recommendations on the changes in the contracts. We delivered the following results to the client: Decreased yearly TP risks valued a material amount for the company; Prepared a TP documentation that grants a penalty protection; Provided an advice on contract management; Developed a price setting mechanism. Based on the results the clients decided to extend the scope of analysis.

Страница изменена: September 11, 2024

Путь: Главная > Кейс > Mitigation of TP risks for an agriculture company

Restructuring for a large consumer products company

Client A large manufacturer of consumer products Background Due to formal and informal sanctions imposed on Russia, many companies faced an urge to change its operating model. On the other hand high regulatory requirements for the manufactured goods, as well as residency in “an unfriendly list country”, creates additional complications and limits the space for maneuver. Objectives Legal, customs and tax analysis of transactions within restructuring, analysis of legal consequences of different business models, advice on the model. Results We performed a cross-functional analysis of customs, tax and legal risks: licensing, labeling, excise taxation on imports and exports, income taxation and VAT. We delivered the following results to the client: Performed an in-depth analysis of legal consequences of different restructuring models; Provided advice on possible alternative models and changes in the law to consider in future.

Страница изменена: September 11, 2024

Путь: Главная > Кейс > Restructuring for a large consumer products company

Analysis of transactions for a pharma company

Client A large pharma group of companies Background The group distributes a part of its products through a number of independent companies registered offshores. These transactions trigger a TP compliance for the supplier and create a risk of fines above 50% of the supply revenue. Meanwhile the counterparties are independent and reject to provide information for a TP analysis. Objectives To develop a methodology for price analysis, analyze available sources of information, perform a benchmarking study of the arm’s length price. Results We analyzed available sources of information, open sources and counterparty data, developed a position and approach to justify the prices in the transactions, and performed a study of the arm’s length level of profitability. We also prepared an alternative study that may be used in case of changes in the functional profile of the parties. We delivered the following results to the client: Performed a benchmarking study and an alternative benchmarking study; Developed a defence strategy in case of a dispute with the tax authorities; Prepared grounds for negotiations with the counterparty regarding the level of prices in the transactions.

Страница изменена: September 11, 2024

Путь: Главная > Кейс > Analysis of transactions for a pharma company

Benchmarking for a real estate company

Client A major office space landlord Background The company operates in an environment where rapid changes in the exchange rate may result in a significant fluctuation of rouble prices in the lease transactions. The company has transactions both with independent and related parties. The Company’s transactions with independent parties are used as a source of market price level information, but the contracts with independent companies will soon expire. Objectives To analyze the transactions with independent parties, external sources of information, develop a price analysis methodology, perform a benchmarking study and a TP documentation. Results We analysed the transactions with independent parties (internal sources of information) and the risks where these transactions are used as a source for an arm’s length price analysis. Further, we analysed external sources of information and prepared reasoning for use of the selected source of information and the method of analysis. Then, we developed an approach to the analysis that complies with the legal requirements and may be replicated by the client. The results reduced the TP risks and substantiated a decrease of a tax burden by more than 10%. We delivered the following results to the client: The tax burden was decrease by more than 10%; Prepared a replicable template and a TP documentation;

Страница изменена: September 11, 2024

Путь: Главная > Кейс > Benchmarking for a real estate company

International TP court practice 2024

Digest of international and Russian transfer pricing court practice for 2024

Страница изменена: January 15, 2025

Путь: Главная > Мероприятие > International TP court practice 2024

International TP disputes, 3 quarter 2024

A quarterly digest of international TP practice - 3Q 2024

Страница изменена: January 15, 2025

Путь: Главная > Мероприятие > International TP disputes, 3 quarter 2024

Transfer pricing in Asia-Pacific

Key global TP trends and their impact on legislation in Asia-Pacific countries

Страница изменена: September 10, 2024

Путь: Главная > Мероприятие > Transfer pricing in Asia-Pacific

First Russian TP dispute: 5 tips to avoid adjustment

Hellow hello

Страница изменена: September 10, 2024

Путь: Главная > Публикация > First Russian TP dispute: 5 tips to avoid adjustment

Russian suppliers of fertilizers at risk: second lost TP dispute

Hellow hello

Страница изменена: September 10, 2024

Путь: Главная > Публикация > Russian suppliers of fertilizers at risk: second lost TP dispute

Accounting services

We provide support to Russian and foreign businesses in building accounting processes in accordance with Russian and international requirements

Страница изменена: September 16, 2024

Путь: Главная > Услуга > Accounting services

Сustoms services

We help businesses to organize operations with maximum efficiency: advice on transaction structuring, reporting and interaction with authorities

Страница изменена: September 16, 2024

Путь: Главная > Услуга > Сustoms services

Сorporate and personal tax

Russian personal and corporate tax services

Страница изменена: September 16, 2024

Путь: Главная > Услуга > Сorporate and personal tax

Changes in Russian TP rules effective from 2024

In this seminar we will discuss what the changes mean for business and when to expect increased attention from the tax authorities

Страница изменена: September 10, 2024

Путь: Главная > Мероприятие > Changes in Russian TP rules effective from 2024

Transfer pricing documentation for a large distributor of spare parts

Client A large distributor of spare parts Background In 2022 the group’s key objective was to organize uninterrupted import of spare parts from counterparties registered in “an unfriendly list” countries to Russia. As a way to achieve this task the company decided to supply the goods through a company registered offshore. The volume of purchases through offshore company was significant and therefore the transactions are subject to a TP control. Because the access to the financials of an offshore company is limited, the client company expected a TP risk. Objectives To analyze the group’s structure and value chain, determine the functional profile of the group’s companies, determine the pricing method taking into account limited availability of data, prepare a TP documentation. Results We analysed the value chain and functional profile of the group companies, available sources of information, possibility to obtain information from counterparties, and a methodology for analysis of the controlled transactions. Further, we documented different scenarious of the analysis and presented the results to the management. We delivered the following results to the client: Prepared a TP documentation and a benchmarking study; Prepared an advice on how to improve the contract management.

Страница изменена: September 11, 2024

Путь: Главная > Кейс > Transfer pricing documentation for a large distributor of spare parts

Russia

Taxes Personal taxation Significant developments Taxes on personal income Residence Other taxes Income determination Deductions Foreign tax relief and tax treaties Other tax credits and incentives Tax administration Sample personal income tax calculation Other issues Corporate taxation Taxes on corporate income Corporate residence Other taxes Branch income Income determination Deductions Group taxation Tax credits and incentives Withholding taxes Tax administration Other issues

Страница изменена: September 16, 2024

Путь: Главная > Страна > Russia

Big changes in Russian TP law are now effective

Hellow hello

Страница изменена: September 10, 2024

Путь: Главная > Публикация > Big changes in Russian TP law are now effective

Transfer pricing

From transactions structuring to benchmarking, preparation of the TP documentation and advance pricing agreements

Страница изменена: September 15, 2024

Путь: Главная > Услуга > Transfer pricing

Kirill Svetlichkin

Experience Large advisory firm — 8 years Head of tax in leasing and high-tech company — 8 years Expertise I specialise in on-going Russian corporate and personal tax advisory. Industry expertise Industries I serve the most are construction, industrial and consumer goods.

Страница изменена: February 2, 2025

Путь: Главная > Сотрудник > Kirill Svetlichkin

Alexander Ryabykh

Experience Head of corporate tax (P) — 3 years Big 4 advisory firm (M) — 6,5 years Head of tax in a financial sector company — 2,5 years Head of tax in a construction company — 2 years Expertise I specialise in Russian tax structuring, M&A and on-going advisory. Industry expertise Industries I serve the most are IT, construction, mining, industrial and consumer goods, retail. Publications I study Russian corporate tax court practice

Страница изменена: September 9, 2024

Путь: Главная > Сотрудник > Alexander Ryabykh

Sergey Kravchuk

Experience Head of TP practice (P) — 3 years Big 4 advisory firm (M/SM) – 6 years Large IT-company (M) — 4,5 years Expertise I specialize on transfer pricing structuring, training and reporting in accordance with both Russian and foreign requirements. My special focus is outsourcing of benchmarking Industry expertise Industries I serve the most are IT, agro, pharma, mining, industrial and consumer goods, retail. Publications I study international TP court practice and share expertise in Russian media: RBC, Economy and Life, speak at seminars and conferences: Interfax, Financial Director, Chamber of Tax Consultants of Russia, advise major consulting companies on TP issues.

Страница изменена: September 9, 2024

Путь: Главная > Сотрудник > Sergey Kravchuk

Cases

Страница изменена: August 19, 2024

Путь: Главная > Page > Cases

Services

Страница изменена: December 12, 2024

Путь: Главная > Page > Services

Blog

Страница изменена: September 9, 2024

Путь: Главная > Page > Blog

About us

At Alip Group, we strive to be a provider of in-depth expertise, elevating the standards of management. We dive, analyze and help you make a weighted decision to resolve the question

Страница изменена: September 10, 2024

Путь: Главная > Page > About us

Events

Страница изменена: September 9, 2024

Путь: Главная > Page > Events

Contacts

Страница изменена: September 9, 2024

Путь: Главная > Page > Contacts

Archive pages

Страница изменена: September 10, 2024

Путь: Главная > Page > Archive pages

Alip Group – Financial and legal advisory

Страница изменена: September 15, 2024

Путь: Главная > Page > Alip Group – Financial and legal advisory

Russian fertilizer manufacturer loses a TP dispute

Hellow hello

Страница изменена: September 10, 2024

Путь: Главная > Публикация > Russian fertilizer manufacturer loses a TP dispute

Russian grain exporter loses a TP dispute

Hellow hello

Страница изменена: September 10, 2024

Путь: Главная > Публикация > Russian grain exporter loses a TP dispute