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Specialist area

Ksenia specialises in tax law and advises major Russian and foreign companies on a broad range of matters relating to taxation. These include, among other things, tax planning, intra-group transactions, transfer pricing, M&A transactions and assessing tax risks and the potential of different business models in the construction, production, retail, logistics, FMCG and other sectors. She also engages in due diligence of the actions and decisions of tax authorities, participates in tax litigation and provides support in tax audits.

Ksenia has extensive experience of successfully challenging decisions of tax authorities out of court and handling various types of tax litigation, including transfer pricing among others, in the commercial courts of different federal circuits. 

Ksenia has more than 20 years of professional experience, and she has an economics degree majoring in Finance and Credit. She is the author and co-author of numerous articles and published materials on tax law, and is an active speaker at seminars and conferences on information sites. She has frequently been involved in preparing draft laws designed to improve tax legislation.

Ksenia is one of the leading Russian experts in tax law according to a major independent international directory The Best Lawyers. She has been marked by World Tax & Transfer Pricing as a leading practitioner in “Tax Controversy” and “Women in Tax Leaders” practice areas.

Main achievements

Ksenia’s recent successful projects include, among others:

  • having the tax authority revoke, at the stage of objections (i.e. pre-trial), 90% of property tax additionally assessed for a major mining company based on the results of a desk audit;
  • providing comprehensive support during a field tax audit of a major taxpayer (developed a legal position for each potential claim, prepared explanations, contacted the tax authority and so on) which prevented the actual implementation of additional tax assessments on transactions with foreign contracting parties; 
  • carrying out a comprehensive tax audit of a foreign company which was a tax resident of Russia with respect to transactions of all types including transactions with securities;  
  • challenging in court taxes that had been additionally assessed for a company specialising in transporting oil cargoes, as a result of which the amount of the tax claims against the company was reduced by 80% or RUB 6.8 billion;
  • successfully challenged in courts additional tax assessments based on claims regarding how expenses were made and deductions were claimed in connection with “bad faith” contracting parties;
  • acting for a company importing pet food, challenging additionally assessed VAT of over RUB 550 million, resulting in confirmation that the company has a right to apply a reduced VAT rate when it sells pet food in Russia;
  • prepared and developed a comprehensive incentive programme for contracting parties in FMCG which has already undergone five tax audits with no claims regarding expenditures being raised by tax authorities;
  • providing support in tax audits for a number of major taxpayers, as a result of which the aggregate amount of additionally assessed tax became insignificant or tax authorities' claims were withdrawn at the pre-trial stage, eliminating the need to litigate to protect the clients' interests;
  • substantiating the prices in and preparing documents for controlled transactions in transfer pricing projects for companies in different branches of the economy;

What they say

An impressive track record in resolving tax disputes and outstanding experience of handling large-scale tax disputes, including representation at the level of the Russian Supreme Court (Chambers Europe).

09.11.2022
Aydar Sultanov has joined Pepeliaev Group's team
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21.10.2022
A draft law has been submitted to the State Duma based on the outcome of the case of PJSC T Plus which Pepeliaev Group’s lawyers won previously in the Russian Constitutional Court
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11.10.2022
The ruling has been upheld of the Commercial Court for Krasnoyarsk Territory regarding the settlement agreement between NTEK and the Russian Federal Agency for Fisheries
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