Tax in Russia
Baker & McKenzie - CIS, Limited’s tax practice has substantial expertise across a diverse range of areas including cross-border tax planning and structuring, the tax-related aspects of M&A, tax disputes and VAT, customs and transfer pricing. The team, which is headed by Alexander Chmelev, also includes Alexander Bychkov, who is a specialist in custom; Sergei Zhestkov, who is experienced in designing the tax efficient structures and M&A-related matters; and Arseny Seidov, who is noted for tax planning and the restructuring of cross-border transactions. Other key figures are Maria Kostenko, who leads on tax disputes and transfer pricing, and recently promoted partners Vladimir Efremov and Kirill Vikulov, who focus on corporate tax, cross-border tax planning and audits.
Dentons significantly expanded its tax practice with the hire of Vasilii Markov and his team from Deloitte Legal and four other practitioners from various firms, including transfer pricing specialist Natalia Bulygina, who joined from KPMG Russia. The 'professional' team, which is led by Dzhangar Dzhalchinov, is praised for 'analysing not only the case but the problem as a whole', 'understanding the needs of a business' and for 'providing sound and reliable legal advice through a tailored approach'. Dzhalchinov has a strong reputation as a tax litigator, in one example he represented Suek before the Supreme Court in a landmark thin capitalisation case, and was able to reverse the earlier judgments of the lower courts. In other matters, he represented Cargill in a dispute concerning the recovery of VAT related to the construction of a public infrastructure project. Markov heads the St Petersburg tax practice where he specialises in domestic tax regulation, corporate taxation and restructuring. Counsel Igor Schikow focuses on cross-border transactions and defence in tax audits and is lauded for his 'attention to detail and outstanding personalised support and involvement at every stage'. Of counsel Anna Zvereva was a new arrival from Bryan Cave Leighton Paisner (Russia) LLP in March 2019.
DLA Piper's team has 'a strong understanding of the local and international tax environment and practice'. Ruslan Vasutin, Igor Venediktov and Elena Mikhailovskaia jointly lead the Russia-wide practice and are regularly supported by associates Bogdan Tereshkevich and Damir Zinnatullin in international taxation and transfer pricing, and senior associate Zaurbek Timaev in contentious tax. Recent mandates include Venediktov advising Gett on international tax restructuring matters and Mikhailovskaia assisting the Avestra Group with a restructuring project and associated currency control issues. In other work, Vasutin is assisting Zara CIS with setting up a tax-effective structure, which involved advising on domestic and cross-border tax regulations, VAT, customs and transfer pricing implications.
FBK Legal has notable expertise in tax planning and domestic and international structuring, due diligence and tax litigation, and counts Glencore International and Russian Fish Company among its list of clients. Nadezhda Orlova specialises in tax structuring and planning and is a popular choice for clients in the oil and gas and energy sectors. Galina Akchurina has 'a strong reputation' in tax litigation; in recent works she successfully represented the interest of Gazprom Dobycha Urengoy in a complex audit case concerning transfer pricing totalling $77m. Tatiana Matveicheva and Dmitry Paramonov focus on tax planning. Tatiana Grigorieva, Alexander Grigoriev and Olga Krivitskaya are recommended for tax disputes.
Pepeliaev Group’s 'client oriented team' maintains a strong reputation for domestic tax regulatory matters, where it is 'highly experienced in tax compliance and the operations of tax authorities', corporate and private taxation and M&A and security market transactions. Andrey Tereschenko is assisting Hitachi Zosen Inova with tax and customs structuring concerning a large-scale waste incineration construction project in Moscow and Kazan. In other matters, practice head and tax disputes lead Rustem Ahmetshin is representing Atrium Europe Real Estate Group in a series of cases challenging the orders of the tax authorities. Andrey Nikonov has particular experience of profit tax, VAT, and mineral extraction tax and Ivan Khamenushko specialises in currency regulation and securities transactions. Valentina Akimova is recommended for transfer pricing and VAT disputes. Managing partner Sergey Pepeliaev is 'a leading expert' in corporate and private taxation. Viktor Arhipov joined Nadmitov, Ivanov and Partners Law Firm LLC and Lyudmila Merkulova is now with Danilov & Partners. Andrey Kirillov was anew arrival from PwC Legal (PricewaterhouseCoopers Legal CIS B.V.).
ALRUD Law Firm is best known for its strong private client and wealth planning tax practice; its team of experienced tax practitioners, including several with a background in accountancy, provides 'assurance' through its 'high-quality advice'. Department head Maxim Alekseyev leads on domestic and international tax restructuring projects, supporting private individuals with tax planning and investment structures, as well as in tax-related disputes. Others to note are counsels Elena Novikova, who focuses on corporate tax restructuring and tax compliance, and Kira Egorova, who acts for private clients on tax planning, succession structure and shareholder agreements. Also recommended are associates Sergey Artemiev, who is ‘deeply knowledgeable of technical issues’, and 'rising star' Elena Skoptsova.
Bryan Cave Leighton Paisner (Russia) LLP's full-service tax practice has a strong reputation as ‘one of the best tax advisory and tax litigation teams in Russia’, according to one client. The sizeable team, headed by the ‘outstanding’ Evgeny Timofeev, who ‘always suggests the most practical and efficient solutions’, attracts domestic and international clients, including Rusklimat, the HeadHunter Group and OBI, with its 'professionalism, sound technical knowledge of tax matters and outstanding experience'. Timofeev is assisting Da Vinci Capital with the preparations for acquisitions of several platforms relating to the setup of a new joint investment fund in Luxembourg valued at $20m. Vladimir Tchikine leads on customs and indirect tax matters, while associate director Sergey Likhachev focuses on tax disputes. Anna Zvereva joined Dentons in March 2019 as of counsel.
Egorov Puginsky Afanasiev & Partners assists a range of domestic, multinational and private clients with cross-border transactions, pre and post-acquisition restructuring and transfer pricing compliance issues, and is also particularly strong in tax-related dispute resolution. Sergey Kalinin heads the practice, where he is regularly supported by senior associates Olga Morozova and Ekaterina Roletr.
Herbert Smith Freehills CIS LLP
Herbert Smith Freehills CIS LLP’s cross-departmental team handles non-contentious matters including tax structuring, planning and post- transactional tax advisory work as well as contentious tax matters. Oleg Konnov and Dmitry Gubarev advised China Chengtong International Investment Corporation on the preparation of a special tax structure in connection with a joint venture with a Russian investment bank.
PwC Legal (PricewaterhouseCoopers Legal CIS B.V.)
PwC Legal (PricewaterhouseCoopers Legal CIS B.V.) considerably expanded its capabilities in tax dispute resolution by hiring 'top-class litigator' Raisa Alexakhina and her 'expert and result-oriented' team from Deloitte Legal. Key strengths include representing Heineken Breweries in a profit tax dispute, and acting for RusHydroin multiple challenges against the tax authorities following a tax audit. Other areas of expertise include cross-border transactions, VAT and transfer pricing. Other key figures include Maria Mikhaylova and senior associates Svetlana Samokhvalova, Pavel Kovalev, Svetlana Klochikhina and Ilya Yakunin.
Boutique tax practice Taxology has notable capabilities in tax disputes, particularly cases against the tax authorities in matters concerning VAT and tax overpayment; in one example, managing partner and 'highly experienced tax specialist' Ilya Mokryshev acted for KFC and Pizza Hut Russia in the return of overpaid tax. Sergey Semenov assisted Don Tabak with transfer pricing and tax compliance issues. In another highlight, 'highly experienced tax litigator' Alexey Artyukh represented T Plus before the Supreme Court in successfully arguing for the limitation on the powers of the Federal Tax Service to conduct tax audits. Mikhail Uspenskiy joined in March 2018 from KIAP (Korelskiy, Ischuk, Astafiev and Partners, Attorneys at Law), bolstering the team's corporate and international tax capabilities.
Andrey Gorodissky & Partners' 'proactive and professional' team has 'extensive knowledge of the Russian tax regime' and 'makes every effort to understand and resolve the issue'. The practice has a strong offering in tax dispute resolution, audits, M&A transactions and for assisting Russian and international corporations with developing corporate schemes. Tax disputes specialist Valentin Moiseev represented Otkritie Management in successfully challenging the decisions of tax inspection authorities in two separate audits. In other work, Moiseev and Evgeny Kalinin are assisting Vardanyan, Broitman and Partners with the tax aspects of a cross-border $116m shares acquisition.
At Clifford Chance, practice head Alexander Anichkin focuses on the tax aspects of customs matters, capital markets and M&A, as well as tax structuring and acts for multinational clients in the media and telecoms, retail and manufacturing industries. Senior associate Dmitry Tolkachev frequently supports Anichkin and is experienced in domestic and international tax matters, currency controls and VAT. The team recently advised Vi Holdings on a real estate joint venture structuring project valued at $1.5bn.
KIAP (Korelskiy, Ischuk, Astafiev and Partners, Attorneys at Law) significantly strengthened its reputation as ‘a go-to firm’ with the acquisition of boutique tax practice, Architecture of Law, in March 2018, with practice head Andrey Zuykov joining the 'highly experienced and solution-oriented' team. Noted for his 'technical expertise, commercial acumen and approachable style', Zuykov recently advised new client Palma Group on international tax and foreign currency control legislation matters in the management of foreign bank accounts. He is also active in several complex tax disputes. Associates Roman Suslov and Evgeny Vasin are other names to note.
KPMG Russia’s 'exceptional, knowledgeable and client-oriented' team is active in tax audits and in complex disputes challenging decisions by the tax authorities for manufacturing and engineering sector clients. Mikhail Orlov and Andrey Ermolaev focus on tax litigation and mediation and are regularly assisted by senior associates Irina Orlova-Panina and Anton Stepanov.
Clients praise LP Law Firm for its 'high level of tax expertise combined with straightforward, practical and well-substantiated assessments'. The practice's expertise spans a diverse range of areas including tax amnesty, corporate tax, domestic and international restructuring, transfer pricing, private taxation and dispute resolution. Key practitioner Lidia Charikova has 'an extraordinary level of tax expertise' and is 'an excellent communicator'; her recent workload includes advising RT-Invest Finance on preparing a tax effective method of financing the construction of a waste incineration plant, and assisting Amond & Smith with a Russian tax amnesty and liquidation tax incentive.
At Noerr, 'professional, reliable and experienced' partners Maxim Vladimirov and Alexander Silakov have notable expertise in transfer pricing, due diligence, international structuring and transactional tax matters. The team advises Porsche on the tax aspects of a car purchase financing programme and the preparation of transfer pricing documentation.
VEGAS LEX has expertise across a broad range of tax matters including domestic and foreign tax structuring, tax support for major infrastructure projects and M&A transactions and customs. Yuriy Ivanov specialises in contentious tax and tax planning; he recently advised Russian Post on taxation and customs clearance matters pertaining to international mail and cargo operations. Denis Kozhevnikov assists Ivanov with contentious tax matters.
ALTHAUS Legal assists domestic and international clients including Gazprom Dobycha Orenburg and DHL with corporate and M&A tax matters. Igor Smirnov advises on a diverse range of tax matters including transfer pricing and cross-border restructuring. He is experienced in advising Russian companies on their foreign operations and Russian subsidies of international companies on tax matters and operations within Russia. Vladimir Shedrov focuses on tax due diligence, audits and M&A transactions. Managing partner Rostislav Shatenok is a name to note for corporate tax.
CMS is regularly instructed by French clients to advise on international tax planning, M&A and cross-border transactions, customs and transfer pricing. Practice head Dominique Tissot specialises in transfer pricing, tax due diligence and restructuring. Hayk Safaryan recently assisted with domestic tax structuring and transfer pricing documentation on behalf of Hi.Sky and Boiron. Givaudan and Herbalife are the other active clients.
Eversheds Sutherland's tax capabilities were bolstered by the arrival of counsel Andrey Grachev, who is now heading the practice, and senior associate Anton Borisichev from KPMG Russia in April 2018. Grachev is 'highly competent, efficient and experienced' in domestic and international tax structures, due diligence and tax dispute resolution, while Borisichev is 'a creative thinker and is able to find multiple solutions to one issue'. Olga Eremina and Daria Korshakova are also names to note.
Infralex’s team of 'proactive and supportive professionals' is particularly known for advising telecoms sector clients on currency and customs regulation; for example, Alexey Popov is assisting MobileTeleSystems and its affiliates with various taxation matters including tax structuring, audits and representation before tax authorities as well as cross-border corporate taxation issues. In other highlights, Popov worked alongside department head Ivan Shienok, Anton Kotov, Zalina Abregova and Philip Gezalov in advising the Russia 2018 Organising Committee on the interpretation and implementation of FIFA and domestic tax regulations, as well as assisting various local organisers of the FIFA World Cup Championships with the tax aspects of business operations. The team further strengthened its capabilities in tax contentious matters, structuring, post-M&A integration and customs and currency regulations with the arrival of 'excellent litigator' Maxim Rovinskiy from YUST Law Firm in April 2018.
At Ivanyan & Partners, practice head Dmitry Mikhailov specialises in tax planning, structuring and tax litigation; he successfully represented Aquanika in a tax audit dispute against the Russian Federal Tax Services. Partner Mark Rovinskiy has expertise in international taxation, including the tax aspects of cross-border and domestic M&A transactions, and restructuring for private and public sector clients. He is also recommended for contentious matters and is representing Fels, a Russian subsidiary of a leading lime supplier, in a precedent-setting dispute relating to the tax treatment of a debt-to-equity swap.
O2 Consulting has 'a strong understanding of international and Russian taxation', currency regulation, transfer pricing, the application of VAT and sales tax in Europe and tax transactions. Managing partner and international transactions specialist Olga Sorokina has been advising Humans Net on the complex multi-jurisdictional tax structuring of a public token sale, one of the first cases related to the tax aspects of a cryptocurrency business. The 'business-oriented' Natalya Kuznetsova assists with the tax aspects of M&A and securities market transactions and international tax structuring and planning for venture capitalist clients and international investors. Senior associate Evgeny Pankratov regularly supports Sorokina and Kuznetsova with international corporate structuring, VAT regulations and the settlement of tax disputes.
At Schekin & Partners, name partner Denis Schekin is active in pre-trial negotiations, tax litigation and audits for domestic and multinational companies in the oil and gas, automotive, education and retail sectors. Other names to note are Elena Bogdanova for transfer pricing and tax auditing and Olga Tsokhorova for international tax planning and structuring.
White & Case LLC is best known for advising domestic and multinational corporations on the tax aspects of cross-border and domestic M&A transactions and major infrastructure projects. Highlights included advising Telia Company on the tax aspects of the US$1bn sale of its 19% holding in MegaFon, a leading mobile telecoms operator in Russia, to Gazprombank. Key contact Irina Dmitrieva focuses on international tax.