Advice on the legislation regarding the controlled foreign companies (CFCs) of Gazprom Export group

Pepeliaev Group's lawyers accomplished a project to assess the tax implications for Gazprom Export LLC in connection with its participation in 44 CFCs registered in 18 jurisdictions. Our experts prepared a memo containing conclusions on the CFC’s entitlement to apply an exemption from the taxation of profit in Russia; we issued recommendations on how to calculate the CFCs’ financial figures and apply exemptions; drafted sample documents and instructions required to fill in the notifications of membership in foreign companies and of CFCs; assessed whether the company was entitled to an exemption from the taxation of the CFCs’ profits; and calculated the CFCs' profits in order to pay tax in Russia. Pepeliaev Group's lawyers have already developed business process roadmaps for the companies to comply with Russian legislation on CFCs.