Advising on the preparation of uniform methodology and the procedure for the calculation of profit generated by controlled foreign companies ("CFC") of the Gazprom group

Pepeliaev Group was selected to advise Gazprom PJSC; it won in a public tender for advisory services in relation to preparing uniform methodology and the procedure for the calculation of profit generated by controlled foreign companies (“CFC”) of the Gazprom group (the scope of the analysis included 90 companies from 30 jurisdictions). The objective of this project was to analyse provisions of the Tax Code with respect to a large number of foreign companies in an actively operating holding structure, and to prepare calculation and methodological approaches that are uniform for the whole Gazprom group to ensure that provisions of the law are complied with and tax is correctly paid in future. One year previously, Pepeliaev Group prevailed in a tender held by Gazprom Export LLC for advisory services relating to similar issues (40 companies from 19 jurisdictions). While implementing large-scale CFC-related projects, which were novel for both the firm and the country, Pepeliaev Group’s lawyers were able to prove their expertise, reassert their cutting-edge experience and prove themselves to be the country’s top advisers in this area.