Managing Partner, Attorney-at-Law
Our tax specialists provide legal advice on taxation, tax planning and managing tax risks. Our lawyers support clients with ongoing tax issues and defend their interests in judicial disputes with tax agencies.
A tax consultant, as a specialist in taxation, is also a highly qualified lawyer able to interpret tax law from a legal point of view rather than in terms of accounting or finance. A tax consultant is no replacement for accountants and finance specialists, but is able to find consistent solutions for the problems clients face, taking all possible outcomes of the situation into consideration and drawing on his or her experience of disputes and knowledge of how the courts operate.
Expertise in tax law
- Advising on individual tax issues and providing a comprehensive legal analysis of the client’s contractual practices and business structure in order to assess the tax risks and opportunities (for example, amendments to company contracts and procedures for cooperation in executing contracts which would reduce the risk of additional tax being assessed or allow for the redistribution of the tax burden)
- Providing consistent legal support throughout the tax inspection process, drafting and submitting objections to inspection reports and appeals against tax agency decisions, thus helping to eliminate disputed additional taxes while still at the tax inspection stage, and defending the client’s position during administrative and judicial appeals. In this way, many disputable claims by tax agencies can be dropped before they are sent to court if the tax agencies are informed of the client’s well-reasoned legal position as drafted by a tax lawyer
- Analysing the taxation aspect and tax risks of transactions while they are being structured and adjusting transactions while they are underway in order to optimize the tax consequences as much as possible, including international transactions
- Tax auditing for transfer pricing purposes
- Tax auditing as part of general due diligence when acquiring companies or as part of a company audit
- Optimizing the tax consequences when companies or individual subdivisions are wound up
- Tax planning for investment
Project pro bono. A successful appeal at the higher tax authority of a decision for additional personal income tax assessment.
А client bought a car on credit. Due to the vehicle complete destruction, the insurance company paid compensation to a bank as a beneficiary. The bank deducted a sum of unpaid loan from the compensation amount, and transferred the remaining money to the client. The tax authority considered the money, paid by the bank is a taxable income. As a result of contesting tax authority decision all the additional charges have been cancelled.
Drafting expert information for the international legal resources portal LexisNexis about the application of the Foreign Account Tax Compliance Act (FATCA) in Russia.
Legal support for a tax audit following tax agency complaints about payments to foreign beneficiaries.
Legal support for a tax audit conducted at a major St. Petersburg construction company further to tax agency complaints about what the agency considered unjustified payments to foreign beneficiaries totalling more than RUB 120 million. Our work resulted in the claims being withdrawn during the objection stage.
Changes to internal structures and interactions in response to the introduction of transfer pricing in the Russian Federation.
Legal assistance in implementing a project changing internal structures and interactions in response to the introduction of transfer pricing in the Russian Tax Code. The client was a leading electronics importer (a group of companies).
Developing a tax structure for the relationship between a developer, investor, contractor and agent within a group of companies.
Developing a tax structure for the relationship between a developer, investor, contractor and agent within a group of companies during the development of a project to construct low-rise housing in the Greater Moscow area. The client was a construction corporation.
Achieving the invalidation of a decision to assess additional profits tax and VAT totalling more than RUB 200 billion further to an application by our client, a major IT distributor.
A successful appeal at the administrative and judicial level of a tax agency’s decision to assess additional profits tax and VAT in connection with what the tax agency considered the unjustified classification of payments for expeditor services and storage services as expenses. The tax agency’s decision (involving a sum of more than RUB 200 billion) was declared unlawful further to an application by our client, a major IT distributor.