The firm provides full scope of legal services related to the taxation of companies and persons and to the application of currency regulation, including:

  • Advising clients on various issues of tax law (including transfer pricing, legislation on controlled foreign companies (CFC), the application of various tax incentives);
  • Health check of companies’ tax obligations;
  • Maintenance of field tax audits, including preparing for the tax audit, challenging the requirements for the provision of documents, etc.;
  • Challenging the results of on-site and off-site tax audits at higher tax authorities and courts, including:
    • Preparing the objections to the acts of field tax audits drawn up by the tax authority, participation in the examination of materials of field tax audits, preparing the appeals to the superior tax authority;
    • Challenging the results of field and office tax audits in the courts;
    • Successful implementation of projects for revising due to newly discovered circumstances of individual judicial acts in connection with a change in the legal position of the Supreme Court of the Russian Federation;
    • Preparing the petitions on measures to ensure the taxpayer’s application (suspension of the action of the disputed acts of the tax authority);
  • Accompanying the interrogation in the framework of tax control by attorney-at-law;
  • Challenging the claims for payment of taxes, as well as refund of overpaid / overpaid taxes with interest;
  • Developing the agreements on the creation of a consolidated group of taxpayers, coordinating of group activities, revising documentation of the termination of group activities;
  • Filling personal income tax declarations for individuals;
  • Advising on the application of currency legislation, drawing up notifications on opening / closing accounts in banks outside the Russian Federation, drawing up reports on cash flows on such accounts in banks.

Significant projects:

  • Challenging the refusal to refund the VAT of a large construction company (the amount of deductions is more than 540 million rubles) in an arbitration court. The entire amount of the deduction is returned to the taxpayer;
  • Supporting the on-site tax audit of a large pharmaceutical company, including: preparing answers to the tax authorities’ demands, studying the documentation and identifying potential tax risks before conducting the on-site tax audit and recommending their elimination, representing the taxpayer’s interests in the tax authority. Possible additional charges were estimated at 200 million rubles, the total amount of additional charges in the inspection report was 1.5 million rubles;
  • Supporting the field tax audit of a large Internet company at all stages. Possible additional charges were estimated at 100 million rubles, the total amount of additional charges in the inspection report was 45 million rubles. The entire amount is contested in objections and in a higher tax authority. The Department of the Federal Tax Service of Russia for Moscow issued a decision in favor of the taxpayer, all additional charges have been removed;
  • Challenging the results of field tax audits of a large communications company and its subsidiaries (additional charges from 150 million rubles to 1.2 billion rubles). Successfully challenged, including, episodes related to the additional assessment of property tax on leasing operations, income tax on payments to members of the company’s management bodies, additional VAT and income tax on unfair counter parties, VAT on the provision of various types of communication services (traffic, rent communication channels), VAT on ancillary services provided to foreign contractors, clarified the procedure for calculating depreciation on new constituent assets;
  • Conducting a series of court cases to amend the taxpayer’s KRSB (write-off overdue debts, “non-existent” debts, “stuck” payments), including with the wording of the requirements “to exclude the taxpayer from KRSB”. Implemented measures to implement the relevant judicial acts. From the taxpayer’s KRSB, “hung up payments” and various outstanding debts amounting to more than 150 million rubles have been written off;
  • Preparing the numerous applications for taking measures to secure a claim in the form of suspension of the contested act of the tax authority, on which positive definitions were made by the courts (no security was provided (bank guarantee, transfer of funds to the court deposit);
  • As part of challenging the results of cameral tax audits (VAT, income tax), judicial practice has been established on recognizing for tax purposes the expenses incurred as a result of hedging the risk of growth in loan rates, as well as on charging and paying VAT when providing communication services to foreign states diplomatic missions;
  • Preparing a memorandum on tax risks and consequences for a group of telecommunication companies with foreign participation, development of draft agreements on the provision of services, adjustment of existing contracts in order to minimize tax risks. Execution and filling of notices on controlled transactions, preparation of responses to the tax authority’s requirements on the said notifications;
  • Preparing a memorandum on the possibility and legal consequences of opening a separate unit by a large dental clinic for the purposes of providing medical services at a new address, participating in a project to develop a new organizational and legal structure of a group of companies.