To get the team

What he specialises in

Rustem has been advising on tax issues for more than 25 years and has, on a number of occasions, represented clients in the Constitutional Court, Supreme Commercial Court, Supreme Court and commercial courts, as well as during out-of-court settlements with respect to additionally assessed taxes.

Rustem’s professional interests are in the area of the taxation of groups of companies, international taxation, and tax administration and control.

His main achievements

Rustem’s major projects include:

  • participated in preparing draft laws, particularly amendments to legislation connected with holding the Winter Olympic Games in Sochi in 2014;

  • participated in and managed a project which involved an analysis and assessment of the tax base for a Russian state-owned holding company based on the legislation regarding controlled foreign companies (over 40 potential CFCs);

  • represented the Far-Eastern Shipping Company in the Russian Constitutional Court in its appeal against the provisions of article 165 of the Russian Tax Code;

  • successfully represented Total in the Supreme Commercial Court in a case on a PSA operator’s right to a refund of VAT;

  • participated in and managed a project aimed at calculating the tax consequences of the foreign member of a Russian business selling operational companies owning non-commercial real estate. Within the project, Rustem’s team provided recommendations as to the documentary evidence of expenses and calculated the withholding tax to be paid;

  • participated in and managed a project aimed at analysing the tax efficiency of a foreign gold mining company's investments in a regional investment project in the Russian Far East. Within the project, Rustem’s team analysed the legislation concerning regional investment projects, then made conclusions about the tax consequences, benefits and risks taking into account the company’s project-related and investment documentation;

  • participated in and managed a project aimed at analysing the tax efficiency and risks pertaining to the activities of a major Russian marketplace. Further to the project, provided recommendations as to mitigating the risks identified;

  • successfully represented JTI in the Supreme Commercial Court in a case on whether intra-group expenses for licence payments were justified;

  • successfully represented Ebner in a litigation concerning the procedure for deducting VAT by the permanent establishment of a foreign entity;

  • successfully represented several companies of the TELE2 Group in disputes over "thin capitalisation" issues and the application of benefits under the double taxation treaty;

  • successfully represented KNAUF in a legal dispute over the classification of intra-group loan financing as an investment activity.

Rustem has on a number of occasions participated in projects that involved advising on issues of the taxation of Russian and foreign companies with respect to domestic and cross-border transactions and the application of the rules of international double tax treaties.

Prominent international directories of law firms such as Chambers Europe, Legal 500, Tax Directors Handbook, Tax Controversy Leaders, Indirect Tax Leaders, and Best Lawyers have rated him among the leading experts in tax law in Russia.

He speaks on a regular basis at tax conferences and seminars.

Rustem has authored numerous articles on Russian and international taxation, and is a co-author of the Tax Law textbook edited by Sergey Pepeliaev (published in 2000, with revisions in 2003 and 2015).

What they say

Clients describe Rustem Ahmetshin as “a well-known local expert with strong experience on the Russian market who always delivers what we need” (Chambers Europe).

Rustem Ahmetshin acts on tax litigation mandates, particularly those with cross-border aspects (Chambers Global).


Pepeliaev Group at the St Petersburg Legal Summit 2024
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Pepeliaev Group and the Consulate General of the Republic of Korea have renewed their cooperation agreement
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Pepeliaev Group's delegation has visited Beijing and Shenzhen on a business mission
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