Our tax practice offers a wide range of services on issues of Russian and international taxation.

Our tax team have extensive knowledge and expertise gained over many years of working in senior positions with leading international law firms and Big4 firms.

Our lawyers have advised a wide range of domestic and international clients with respect to their activities in Russia, holding and investment structures in various jurisdictions (including investment funds), as well as issues related to corporate restructuring and IPOs of Russian issuers on international stock exchanges. Our team have provided legal support to clients conducting business in sectors including aviation, real estate, consumer industrial products, telecommunications, pharmaceuticals, oil & gas industry, retail and other.

In our work we adhere to international standards for legal business. We can offer a tailored approach to projects of any complexity and hands-on partner involvement in each project.

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The services offered by our tax practice include:

  • Advice on complicated issues of Russian and international corporate taxation
  • Tax reviews aimed at discovering tax risks and advising on the ways to mitigate these risks
  • The development, review and implementation of international holding structures
  • Tax support for international activities of the company, including financing and operations
  • Tax support in M&A deals, including tax due diligence and deal structuring
  • Advice on transfer pricing issues and preparation of transfer pricing documentation
              Advising a joint venture engaged in the construction of commercial and residential property in Russia on tax matters in connection with a multi-functional development project in the Moscow Region, including structuring advice on tax effective contractual arrangements with investors and anchor tenants, project financing and foreign holding structure.
              Our lawyers' representative experience (including in prior firms)
              Advising a large international pharmaceutical company on tax matters related to the construction of manufacturing facilities and subsequent manufacturing of pharmaceutical products in Russia, including structuring of Russian operations and application of regional tax incentives for investors.
              Advising a large multinational manufacturer of telecommunication equipment on tax aspects of the restructuring of its Russian distribution chain and transition to a new business model of acting through a Russian subsidiary (a limited risk distributor), including transfer pricing issues and the determination of the customs value of imported equipment, as well as financing of the Russian subsidiary.
              Advising a Russian holding specialised in investments in commercial real estate on structuring of international holding and financial structure on the base of a foreign investment fund.
              Comprehensive analysis of transfer pricing and preparation of transfer pricing reporting under the Russian standards for a Russian subsidiary of a large international pharmaceutical group.
              Successful assistance to a high-end medical clinic with a complex tax audit involving the review and challenge by the Russian tax authorities in respect of the applicability of reduced withholding tax rates envisaged by an applicable double taxation treaty using the concept of beneficial owner.
              Advising a large multi-national chemicals manufacturer on the applicability of the reduced tax rates under a double taxation treaty in view of the concept of the beneficial owner having been introduced in Russia.
              Assisting the client with the determination of the beneficial owner of the income and preparation of the defence file for the Russian tax authorities. Advising on the potential changes when MLI comes into force.
              Advising an independent private equity investment manager on various tax issues related to their activities in Russia, including application of the CFC rules to their Russian investors and investing through a Russian investment partnership.
              Advising the UBOs of a taxi aggregator company on tax efficient methodologies for the sale of the business.
              Advising a large fashion manufacturer and distributor with production and distribution entities in various CIS, European and Asian jurisdictions on recommended changes to its holding structure, financing model and the holding of IP.
              Advising a large fashion and fragrance business on Russian tax issues related to the implementation of a share-based employee benefits plan.
              Advising investors on the tax efficient structure of financing the construction of an interactive children's park in the US.
              Advising a major Russian lessor on tax aspects of structuring of its international operations.
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