Moot Court on Tax Law

Track: Moot Courts

Description

The session will be conducted in a popular moot court format and will address controversial issues of taxation of controlled foreign companies, as well as certain other topical issues of tax practice.

The event is unique since a taxpayer’s rights are going to be defended by representatives of the Federal Tax Service of the Russian Federation, while interests of the tax office will be represented by legal community members.

The discussion is planned to address the following issues:

  • Tax aspects related to foreign creditor’s assignment of claim to a Russian debtor, which includes the amount of accumulated but unpaid interest;
  • Rules of taxation of controlled foreign companies’ income received in the fiscal year 2015, if a taxpayer, being a tax resident of the Russian Federation, took control of the foreign company in 2016;
  • Tax liability for failure to notify about a controlled foreign company when such company’s income is not accountable to the controller;
  • Limitation of exemption provided in Article 251, Paragraph 3.4, Part 1 of the Tax Code of the Russian Federation concerning interest income in debt release.

The session will be divided into four parts:

  • Introduction;
  • A “court hearing” including all main stages of proceedings;
  • Deliberations and adoption of the judicial act;
  • Concluding remarks of participants regarding the reasoning behind the decision.

Taxpayer side:

Daniil Egorov

Deputy Commissioner, Federal Tax Service

Tax authority side:

Dmitriy Mikhaylov

Partner, Ivanyan & Partners

Mark Rovinskiy

Counsel, Ivanyan & Partners

Judges:

Tatyana Andreeva

Former Deputy Chairman, Supreme Commercial Court of the Russian Federation

Viktor Batsiev

Chief of Staff, Supreme Commercial Court of the Russian Federation (retired)

Elena Valyavina

Judge, Supreme Commercial Court of the Russian Federation (retired)


*This schedule may be subject to change