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Tax law and tax disputes

Tax law and tax disputes

The tax practice is one of the key practice areas at Pepeliaev Group. More than 60 lawyers including 14 partners at our firm deal with the issues of analysing tax risks and minimising them.

Pepeliaev Group - Law Firm of the Year.

Pepeliaev Group’s tax expertise is considered to be among the very front rank in Russia. Independent ratings and international publications have acknowledged this on numerous occasions, recommending our lawyers as ‘outstanding specialists’.   

We are members of the international association Taxand . Our knowledge of the intricacies of international taxation that the network’s experts have allows us to safeguard business interests taking account of international experience.

We offer our clients a wide range of services and ensure an integrated approach to handling issues that arise in a company’s day-to-day operations and strategic decision-making. Legal-500-top-tier-firms-2020.jpg


Advising in the following areas

  • Legislation on controlled foreign companies (CFCs) and deoffshorisation
  • Transfer pricing
  • Tax support in a company’s and in a group’s day-to-day operations 
  • Taxation of mineral resource use 
  • Administrative and judicial practice with respect to profit tax, VAT, corporate property tax, tax on securities transactions, etc.
  • International taxation
  • Taxation in the context of investment activity
  • Tax audit
  • Advising individuals on taxation issues, drafting and submitting tax returns 

Resolving disputes

  • Providing support during field and desk tax audits as well as audits with respect to compliance with the transfer pricing rules
  • Challenging the results of field and desk tax audits 
  • Settling disputes in and out of court Providing support during negotiations with tax authorities with respect to entering into a settlement agreement 
  • Protecting the client’s interests in disputes regarding whether a tax benefit is justified and whether the taxpayer has acted in good faith 
  • Having the costs of legal representation and other court costs reimbursed
  • Participating in proceedings to have tax paid in excess reimbursed 
  • Conducting cases relating to VAT refunds
  • Defending clients when the legislation on criminal liability is applied

Tax registration of foreign companies providing electronic services to individuals and legal entities

  • Assistance with determining whether a company is required to be registered with the Russian tax authority
  • Help with registering a foreign company with the Federal Tax Service
  • Help with calculating tax and preparing a tax return
  • Filing a VAT return with the tax authority through the taxpayer’s personal account or through the operator of an electronic document management system
  • Representing the client before the tax inspectorate, which includes preparing answers to the requests of tax authorities
  • Clarifying the effective rules of all branches of legislation with respect to foreign companies’ activities in Russia


The President Of Russia has backed the suggestions of The Russian Chamber Of Commerce and Industry developed together with Pepeliaev Group's experts regarding the regulation of various payments similar to taxes and levies

The Russian Chamber of Commerce and Industry commissioned Pepeliaev Group to analyse various payments which are similar to taxes and levies but are not included in the Russian Tax Code. These payments are collected in the most diverse industries and increase the real burden for businesses to finance their public commitments. It actually means that a parallel tax system is created. The amount of such payments already exceeds RUB 700 billion (1% of GDP). One of the most recent examples is the charge on 12-ton trucks, which sparked a massive public outcry.

The work completed is aimed at normalising such payments, i.e. at regulating them in a systematic manner. To implement this, several directions for improving legal regulation have been suggested.

Firstly, a single exhaustive list (register) of all mandatory public payments is needed. This is necessary to provide a realistic and accurate assessment of the burden that such payments represent for business, what they cost to administer, the level to which they are collected and their useful effect.

The results of the study were presented to the professional community at the workshop "Taxes of a non-tax nature: A systemic approach" which took place on 4 December 2015 within the framework of the XI All-Russian Tax Forum of the Russian Chamber of Commerce and Industry (see the recommendations given at the workshop at

The study demonstrated that developed foreign countries also face the same problems with collecting public payments. At the same time, Pepeliaev Group's managing partner, Sergey Pepeliaev, believes that this may not be treated as a justification for the current situation: "The aim of the proposed measures is to build up in Russia the world's best practice of collecting mandatory public payments". Vadim Zaripov, head of Pepeliaev Group's analytical department, agrees with this: "The regulation of payments which are similar to taxes and levies may essentially become the second significant step in the country's tax reform, some kind of 'tax reform 2.0'. If the suggested measures are implemented as they were conceived, this will not only help broaden the economic freedoms of Russian entrepreneurs in the context of external sanctions; it will also ensure that socially important goals are properly financed". Per Popov, a senior associate at Pepeliaev Group, who participated in the preparation of the study, points out that "public payments which are not included in the Russian Tax Code, are not only similar to taxes and levies; they indeed are taxes and levies without being referred to as such in legislation. They are said to have a non-tax nature by convention, just because they are not set out in the Tax Code".

Tax support for the export of medicines The lawyers of Pepeliaev Group's tax department have supported transactions aimed at exporting medicines into foreign markets.
The lawyers of Pepeliaev Group's tax department have supported transactions aimed at exporting medicines into foreign markets. Our objectives comprised analysing the export contracts, the agreements for the transfer of the technology of manufacturing medicines, for the manufacturing of a medicine in facilities abroad, and for organising clinical trials, and other documents in the sphere of selling and marketing such medicines. Our experts analysed the tax risks and adjusted the contracts taking into account the need for such risks to be mitigated; they also negotiated on tax matters with foreign and Russian counterparties; advised the client on all aspects connected with the manufacturing and sale of medicines in foreign markets.
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