Tax dispute resolution:
Tax structuring, consulting, tax-related business support:
- Pre-trial settlement of tax disputes (objections against audit reports, preparing complaints to superior tax authorities)
- Appealing in court against decisions following tax audits, actions/omissions of tax authorities and officers
- Legal disputes to recover losses caused by tax authorities
- Legal assistance in obtaining VAT refund, tax refund
- Creating legal precedents in the implementation of tax planning strategies
- Support during desk and on-site tax audits
- Preparing for, and support during questioning
- Protecting company management and owners against subsidiary liability for the company’s tax arrears
International tax planning:
- Transaction structuring
- Tax examination of contracts, groups of transactions, investment projects
- Tax structuring of business
- Tax Due Diligence
- Preparing for tax audits
- Tax audit
- Identifying tax reserves and overpayments
- Analyzing tax risks
- “Second opinion”: revaluation of tax risks and stress testing
- Verbal and written consulting on tax-related aspects of current operations
- Consulting on international taxation, including double taxation treaties, foreign corporate income tax, VAT on cross-border transactions, withholding tax
- CFC-related consulting, analysis, and structuring
- Consulting on automatic and two-way financial data exchange
- Consulting on tax and currency residency
- Analyzing foreign exchange legislation
- Consulting on amnesty of capital
- Successfully represented a Russian private investment company, a major owner of Class A office real estate in Moscow, in commercial courts in a landmark case for RUB 31 million, related to the non-assessment of property tax on a fixed asset after commissioning and until completion of all fit-out works in the building. Successfully contested all claims brought by the tax authority.
- Represented a major Russian private water supply and discharge operator in commercial courts of three instances in a case related to carrying prior year expenses to the current period according to Article 54 of the Russian Tax Code. All claims brought by the tax authority were successfully contested, for a total of RUB 20 million.
- Successfully defended a Russian company, the only domestic producer of medical products for patients with sensitive needs, in commercial courts of three instances in a case regarding business splitting. The total claim amount exceeded RUB 100 million. Successfully contested 100% of claims brought by the tax authority (80% in a pre-trial procedure, which is faster and less costly for the client, and 20% in arbitration).
- Successfully represented a leading Russian industrial real estate developer in Russia in commercial courts in a case in connection with a rejected VAT refund in the amount of RUB 180 million. Successfully contested 100% of claims brought by the tax authority.
- Successfully represented a Russian company operating in forestry and wood processing in a pre-trial contestation of claims regarding cooperation with unscrupulous contractors. The client received a VAT refund exceeding RUB 25 million in a pre-trial procedure.
- Successfully represented a Russian television company operating as part of a leading media holding company in Russia and Eastern Europe and owning assets in all segments of the media market, in a case related to unscrupulous contractors, controlled debt (thin capitalization), and tax recharacterization of transactions for a total amount exceeding RUB 80 million.
- Successfully represented a major Russian company in the food industry in commercial courts of three instances in a case regarding the invalidation by tax authorities of transactions and application of the consequences of their invalidity in the form of additional tax assessment. Successfully contested 100% of claims brought by the tax authority.
International tax planning:
- Advised a privately-owned Russian financial group, one of the top 35 major Russian companies, one of the top 5 leaders in the financial sector, and the largest private company in the segment according to RBC-500, regarding the tax consequences of applying Russian CFC rules, including the analysis of existing group structures, analysis of the implementation of CFC-related novelties in the Russian legislation in the international tax law system and national laws of other jurisdictions, and analysis of tax residency and foreign exchange legislation matters.
- Advised a leading Russian real estate developer, owner and manager of retail centers operating in the Moscow retail property market, on accounting and reporting matters (IFRS, tax authorities, banks). Jurisdictions: the Netherlands, Luxembourg.
- Successfully defended a Latvian-based television company before its Russian contractor regarding VAT payment.
- Advised a top manager of a leading Russian and global mineral producer and exporter
regarding the analysis of the novelties in the Russian legislation concerning the amnesty of capital, their implementation in international tax law and national laws of other jurisdictions.
Structuring in Russia (consulting, tax due diligence, tax audit, etc.):
- Carried out a tax audit of a Russian company, the only domestic producer of medical products for patients with sensitive needs, to prepare for an on-site tax audit and to identify tax reserves.
- Advised a subsidiary of a leading telecommunications operator in Russia and CIS regarding preferential tax treatment in respect of Skolkovo residents.
- Advised a Russian privately-owned financial group, one of the top 35 major companies in Russia and one of the top 5 leaders in the financial sector, to develop a mechanism for applying VAT credits in a questionable, unregulated situation.
- Carried out tax audit of, and provided advice to, a major Russian private water supply and discharge operator to identify internal tax reserves of prior years and report them in the current period.
- Advised a strategic town-forming enterprise on offsetting additional tax assessments resulting from an on-site tax audit, without contesting the decision based on the audit results.
- Prepared and provided support during the questioning by tax authorities of a top manager of a leading Russian industrial real estate developer.
Advised to heirs of a world-renowned author regarding the most favorable tax regime in connection with copyright management.