Category Archives: Court cases and rulings

Tax Alert about Deoffshorization in Russian Federation from EY (17 February 2015)

Tax Alert from Ernst & Young dated 17 February 2015 “Deoffshorization in action: A fast developing practice”. Analysis of several recent court cases to illustrate the practical approaches and methods that the Russian tax authorities are already applying to structures with an international component (Equant LLC case, Sunrise Tour LLC case, Avtotor Management case, Oriflame… Read More »

Court cases about conduit companies (Nestle case, Moscommerzbank case, Credit Europe Bank, Naryanmarneftegas case)

1. Nestle case 2015 (case #A40-16883/15, in favor of tax authorities) Nestle Finance International LTD (NFI) & NTC-EUROPE SA (NTC) lended money to Nestle Russia. Courts decided that: – real lender is NESTLE S.A. (parent company of Nestle Group) – NFI & NTC are just conduit companies, used only for proper compliance with the tax law… Read More »