Master Lawyer Alexey KOROL in Minsk, Belarus

TAX CONSULTATION

Permanent Establishment:

• Assessing the tax risks for large foreign companies related to their recognition as permanent establishments in Belarus, providing practical recommendations to prevent and minimize the negative consequences associated with it;
• Advising an international pharmaceutical company on the risks related to its recognition as a permanent establishment in Belarus, adjusting the company's international policies in accordance with applicable Belarusian laws;
• Consulting a permanent establishment of a large international holding in the healthcare sector on issues related to its registration with state authorities;
• Evaluating the risks associated with recognizing a large engineering company as a permanent establishment in Belarus, considering the factual circumstances and the nature of the company's employees' activities in Belarus, and providing practical recommendations to prevent and minimize the negative consequences.

Transfer Pricing:

• Advising a large Belarusian-American company on legal regulation of the activities of affiliated parties in accordance with current Russian laws, including tax differences in the case of identification of affiliation between taxpayers, regulation of transfer pricing for tax purposes, and tax control over transactions between affiliated parties;
• Providing advice on compliance with transfer pricing rules, offering practical recommendations to ensure that the prices used in contracts correspond to market price ranges and pricing methods.

"Google Tax":

• Advising international companies on the application of VAT calculation and payment rules in Belarus for electronically provided services (internet services) ("Google Tax").

Other Tax Matters:

• Advising an international online marketing center on market entry into Belarus, providing advice on the tax structure for businesses;
• Consulting a large international food manufacturer on tax issues related to accounting for payments under a licensing agreement;
• Providing tax advice to individuals, including drafting and filing tax returns.

TAX DISPUTE RESOLUTION

• Assisting in internal and external tax audits, contesting their results. Judicial and pre-litigation settlement:
  • Drafting objections, contesting tax authority decisions on various tax issues (corporate income tax, VAT, permanent establishment, invalidity of certain accounting documents, etc.), resulting in a reduction of the additional tax amounts charged to certain clients by 600,000 Belarusian rubles (total for 2017);
  • Contesting additional VAT charges by a large Belarusian company due to the invalidity of several accounting documents (Presidential Decree No. 488 of October 23, 2012), successfully protecting the client’s interests (completely avoiding additional payments) by establishing that the decree provisions did not apply to the case at hand;
  • Attending an off-site inspection by the State Committee for Standardization of a large Belarusian factory, successfully avoiding any repercussions for the client.

Other Experience:

• Legal support for the cultural event "FSP Art Picnic" (2015, 2016, 2017);
• Mentorship at TeenGuru Business Academy;
• Co-author of a practical guide for tax advisors "Tax Aspects of Civil Law Relations";
• Practicing at common law courts.

EDUCATION:

• Belarusian State University, Faculty of Law, Specialization: Tax and Banking Law;
• Institute for the Re-training and Advanced Qualification of Judges, Prosecutors, and Legal Professionals of Belarusian State University, Advanced Training, Academic Discipline: "Defense Lawyer's Activities in Criminal Proceedings."