# 3. Autumn Marathon

Dear readers,

We are glad to welcome you to our new edition of “Korpus Prava.Analytics”.

Articles of our autumn edition answer interesting and topical questions. One of the key topics remains the third stage of the capital amnesty, which will last until February 29, 2020. This time Tatiana Frolova takes a close look at the process of redomicilation of foreign companies to the Russian Federation. It should be noted that redomicilation has become the main condition of the current amnesty.

“Invest one third in real estate, one third in business and another one third in gold”. Is this the right approach to the family capital formation in the long term? Dr. Ariel Sergio­ Goekmen, a board member of Schroder & Co Bank AG, Zürich, answers inter alia this question regarding the preservation of the family wealth for numerous generations.

Julia Vints dedicates her article to peculiarities of the updated standard for accounting of financial instruments IFRS 9. You will learn about the key changes to the classification and evaluation of financial assets, as well as the difficulties companies face when applying­ new rules for impairment of financial assets.

The latest issue once again returns to BEPS plan, only now we will analyze the issue relevant for 2019 in more detail, i. e. requirements of offshore jurisdictions on arrangement of economic substance as part of the said plan.

In recent years, regulatory authorities have focused a lot on the application of the concept of the beneficial owner of income. For his article, Alexey Oskin, deputy director for tax and legal practice, has prepared an extensive collection of recent court decisions related to the application of this concept.

We hope this feature material will be really beneficial for you. We look forward to your recommendations and questions, and we will do our best to cover them in our next edition­ or news feed on our website or Facebook page.

Enjoy reading!

Artem Paleev
Managing Partner
Korpus Prava

Svetlana Sviridenkova


Audit Practice

Korpus Prava (Russia)

When making a decision to purchase property (fixed assets) under the financial lease (leasing) agreement, a business owner rarely thinks about peculiarities of accounting and tax consequences that this method of acquisition will entail. In the financial lease agreement, it is necessary to indicate on whose balance sheet a leased asset is accounted, as this affects­ accounting and tax accounting of the purchased car.

Julia Vints


IFRS Practice

Korpus Prava

In preparation of financial statements in accordance with IFRS (International Financial Reporting Standards) for 2018, all companies faced with a new financial instrument accounting standard IFRS 9. Financial instruments have traditionally raised the greatest number of questions and presented many challenges. IFRS 9 mandatory for use since January 01, 2018, was intended to eliminate the shortcomings of then applicable IAS 39, simplify the logic of classification of financial ins [...]

Tatiana Frolova

Leading Lawyer

Korpus Prava Private Wealth

In June 2019, Russia started the third stage of the capital amnesty, which will last until 29 February 2020. The main condition for the current amnesty was the return of the declared assets to their homeland. It should be noted that not all assets are subject to repatriation, but only funds deposited in foreign accounts and foreign companies, which are to be redomiciled to the Russian Federation. Redomiciliation is a mechanism for changing a company’s jurisdiction and transferri [...]

Irina Kocherginskaya, LL. M.

Managing Director

Tax and Legal Practice

Korpus Prava

Since 2013, when the OECD published its report on combating corporate tax base erosion and profit shifting to low-tax jurisdictions, commonly known as the BEPS plan, we have repeatedly returned to issues associated with implementation of the BEPS plan in the pages of “Korpus Prava.Analytics”. One of the topical subjects of the current year is requirements of offshore jurisdictions for organization of economic substance. In this article, we will try to answer the questions as to what it means, what is the reason for their introduction, whether they should be observed and what to do next.

Alexey Oskin

Deputy Director

Tax and Legal Practice

Korpus Prava (Russia)

In May 2019, the Federal Tax Service summarized the law enforcement practice in disputes in which the tax authorities established that international agreements had been abused. In particular, the concept of “person beneficially entitled to income (beneficial owner)” is widely used as a universal instrument to combat abuse.

Irina Otrokhova

Chief Compliance Officer

Corporate Services

Korpus Prava (Cyprus)

A few years ago, the procedure of opening a bank account for business was not unusual and was not associated with any complex procedures. Relations between businesses and banks were based on trustworthy partnership, but in recent years the world has changed a lot.

Dr Ariel Sergio Goekmen

Member of the Executive Board

Schroder & Co Bank AG, Zürich

These rays of the star of doom can be categorized into reasons closely tied to the family itself, ranging from bad investment or business advice to bad implementation, bad business decisions, divorce — Mr Bezos comes to mind — family conflict, which sometimes even blocks a family business from thriving, no mutually shared family values, no discipline, family fertility with many offspring, which have to divide the inheritance, expensive lifestyles, expensive hobbies, drug addiction and drug abuse to mental insanity.