Maria Rybitskaya

Advising:

• a holding company on restructuring options for an FMCG asset with the aim of utilising accrued tax losses, including designing an optimal structure with minimal tax risks
• a private client on structuring options for transferring Russian assets from a Cyprus holding to an individual foreign tax resident and their close relative who is a Russian tax resident
• a gas industry company on jurisdictional structuring across more than 15 foreign jurisdictions (including Bahrain, Oman, Hong Kong, the UAE, China, Mauritius, Macau, etc.), including an analysis of the advantages, limitations, and practical aspects of establishing a trading company
• a gas industry company operating in a special economic zone, providing comprehensive tax support for more than three years during the construction and launch of production facilities, including contract analysis, tax risk assessment, and matters of separate accounting
• a retail group on business separation (asset carve-outs), taking into account tax risks, value enhancement, and improved business flexibility, as well as the utilisation of accrued interest losses on an acquisition loan at the SPV level
• a real estate group on structuring the disposal of interests in Russian asset-holding companies by foreign shareholders
• the family office of a high-net-worth individual on transferring private assets (real estate, vehicles, shares/interests) from foreign entities to individuals or Russian entities, including CFC implications
• a Russian IT company (Skolkovo resident) on developing a position to challenge a tax audit that denied eligibility for IT tax incentives
• a holding company on CFC matters, including analysis of corporate documentation and control mechanisms (both formal and informal) to assess the risk factors in being classified as a CFC
• a mining company on separate accounting in priority development areas (TOR), capitalisation of costs at the commissioning stage, and insurance recoveries
• more than six companies in the oil & gas and chemical sectors in the context of tax due diligence, including analysis of a draft amicable settlement agreement
• a holding company on the tax model for a tourism and transportation project in the Russian Far East, involving preferential regimes
• a gas industry company on structuring the financing of a gas transportation system in Russia with a focus on tax-efficient solutions
• a technology group on Pillar 2 matters, including modelling potential impacts under transitional rules
• foreign companies on redomiciliation to Russia, the UAE, Kazakhstan, Qatar, and other jurisdictions, including analysis of exit implications from the Netherlands, Switzerland, Cyprus, etc.
• holding and operating companies (including public companies) on redomiciliation from the BVI and Cyprus to Russian special administrative regions (SARs), including support in especially complex cases
• a diversified holding group on obtaining tax incentives for international holding companies (IHC) in SARs
• a major construction group on tax residency migration, including analysis of the tax efficiency of existing structures and successful redomiciliation from Cyprus to Russia