App development company, Russian beneficiary, solutions to avoid CRS?

Situation is as follows:

There is a Seychelles company,
There is a Russian company (OOO),
Beneficiary for both companies is a Russian citizen.

Goal:
Have income from Google and Apple go to an offshore account to reduce tax, transfer only necessary amounts to pay salaries to Russia.

What options are there now that Russia is also joining CRS and exchanging information?

Obviously beneficiary which is Russia resident does not want his tax inspection to get information about his offshore company accounts.

Apple and Google can send money to any account and any company.

Are there any structures for this?

EMIs? Nominees? Banks that don't report?

Also, is it realistic to empty the account before 31st of December so it gets reported as having 0$?

GCE said:

Hello,

you can try with non-reporting country like Georgia - establish company there and open local bank OR open bank account with Georgian bank for foreign business entity. Thus you will have your problem resovled at least for several months.

If your client does not want to appear anywhere and have troubles with Russina tax inspector, he should start from scratch moving the entire structure out of Russia.

Well, it is mostly working from home, so company can be registered ANYWHERE. Also, would it work registering a bank account in Georgia for a Seychelles company?

Are there any banks you could recommend in Georgia that would open account for Seychelles company?

Well, EMIs are one option I guess. I'm not sure what is so special about Cyprus? They are still part of CRS.