Services
Tax
Disputes
In spite of the fact that the number of winning taxpayers in disputes with tax authorities tends to decrease steadily, Taxology keeps obtaining beneficial tax rulings for their clients in the absolute majority of cases.

It is known from experience that the lawyers' efforts are particularly most effective during pre-trial procedures aimed at settlement a tax dispute. Even if the dispute is submitted to court, nothing is lost yet, and our lawyers will be eager to make the utmost use of their vast litigation experience to protect the rights of taxpayers.
Taxology is proud of a lot of cases won both with tax authorities and courts of arbitration of all instances in the most regions of Russia. Details of some of them are available from our web site.
PROJECTS
Representing an agro-industrial complex's interests in a dispute over unjustified tax benefits for intra-group services
Challenging over RUB 450 million tax claims filed against a large-scale chemical enterprise for accruing depreciation while failing to sign an operational acceptance certificate
Representing several airlines in disputes over retrospective insurance premiums increase for more than RUB 900 million resulting from adoption of a federal law that was eventually declared unconstitutional
Representing a chemical enterprise in a precedent-setting dispute regarding the refund of RUB 1.1 billion tax overpayment resulting from accounting for the man-made accident clean-up costs
Legal representation of a major bank in a dispute over RUB 400 million additional charges on cross-border securitization transactions
Tax
Refund
Tax reserves (potential) mean hidden tax overpayments arising from underusing the opportunities provided by law (tax benefits, deductions, expenses).

Taxology experience shows that nearly every taxpayer has overpayments, and their refund is a completely transparent and legitimate procedure without significant risks.

Taxology services cover all the necessary steps: from the primary analysis of tax reserves to their actual refund by the tax authority and legal defense in the event of a dispute.
Advantages of retrospective overpayment refund: real economic effect from tax refund (credit), the absence of risks of additional penalties and fines, a positive methodological precedent case on a disputed issue for the future.
PROJECTS
Supporting a federal retail giant in refunding about RUB 1 billion tax overpayment
Comprehensive support of refunding over RUB 750 million tax overpaid for a food producer
Supporting the refund of RUB 800 million tax overpayment as a result of an increased depreciation factor used at a producing company
Comprehensive advice to a trading network on refunding over RUB 500 million income tax overpaid
Pre-trial refund of RUB 340 million tax overpayment for a major airline
Advising
In the course of its operations, any company wonders how to correctly account for certain operations, choose a specific option or assess the risks with constantly changing laws, explanations and judicial practice.

Taxology's tax advice group involves professionals with experience in major Russian audit firms, the "big four", tax authorities, which allows to provide comprehensive tax advice of any complexity taking into account diverse practical skills.
Subscription-based tax advice is highly-demanded by major Russian and foreign holdings. On top of verbal and written advice, Taxology subscribers get recommendations on in-house audit reports and free invitations to educational seminars.
PROJECTS
Advising a mining equipment supplier on foreign exchange regulation and CFC laws
Advising major taxpayers on the tax implications of introducing a loyalty program
Development of R&D expenses, financial investments, forward transactions, assets in trust accounting guidelines for a chemical giant
Development and introduction of accounting policies for accounting and tax accounting for the benefit of major taxpayers, including those having extensive branch networks
Accounting and tax accounting setup for a major financial company
Tax
Audites
It is quite challenging to pass a tax audit with minimum stress, not revealing extra information or allowing the tax authorities to go beyond their powers.

Taxology lawyers have experienced hundreds of tax audits and will help your business to build a constructive dialogue with the tax authority, will accompany tax control measures, including examination of witnesses, inspections and seizures, advise when and what documents to give with the necessary explanations, and when the tax authority acts unlawfully.
Audit is the initial stage of a tax dispute, which can be prevented by timely working on evidence and substantiation of a position on a disputed episode before the tax authority.

Competent audit support significantly increases the chances of settling a tax dispute out of court.
PROJECTS
Supporting a field tax audit of a telecommunications holding with about RUB 1 billion total claims
Pre-trial reduction of the penalty for late personal income tax remittance by an oil and gas company
Pre-trial appeal against claims filed against a Russian airline for a failure to deduct VAT on cross-border leasing payments in the amount of more than RUB 500 million
Pre-trial appeal against RUB 200 million tax claims for the benefit of a major trading network
Pre-trial appeal against the results of a field tax audit of a production company for more than RUB 500 million
Transfer
Pricing
With transfer pricing, Taxology clients are particularly interested in the rationale for choosing a pricing method or a combination of methods, as well as correct application thereof, price adjustments in non-standard situations and risk mitigation in controlled transactions.

Our services often include an extra option: tax dispute support, if the market price calculation prepared by us is challenged by the tax authority.
We were among the first to start winning judicial disputes regarding new transfer pricing rules, and then we set a precedent at the level of the Supreme Court of the Russian Federation.
PROJECTS
Drawing up documents justifying the market price level using a combination of methods for a chemical industry leader
Трансфертное ценообразование
Drawing up documents to justify the prices used in transactions worth over RUB 600 million for a Russian-Norwegian oil producer
Трансфертное ценообразование
Development of transfer pricing documentation on intercompany supplies and services to the benefit of an agro-industrial holding company
Трансфертное ценообразование
Drawing up 5 transfer pricing packages on sales transactions and equipment rental for a diversified holding
Трансфертное ценообразование
Drawing up documents demonstrating that the interest rate used in intercompany financing transactions of a big developer holding company is a market one
Трансфертное ценообразование
Tax
Benefits
Despite a downward tax benefits trend set by the government, there is still much room for taking advantage of them.

Benefits may be provided both at the federal and regional levels. Commonly it is quite confusing to get and use them, and in most cases the right to benefits is conditional upon entering into special agreements with state bodies.

Tax benefits approval and obtainment is a transparent and lawful process that requires considerable time and professional approach in preparing the rationale for, financial models and definitions of the benefits, as well as contractual terms and conditions for getting them
Taxology lawyers have a record of success in obtaining tax benefits across Russia, as well as their subsequent judicial and pre-trial defense in case of a tax dispute.
PROJECTS
Assisting a dairy leader with applying a regional investment benefits in the amount of RUB 125 million
Developing a special investment contract implementation costs accounting concept for the biggest mineral fertilizers producer, which prevented over RUB 500 million tax risks
Supporting a food producer in obtaining regional tax benefits for a project with the amount of investment exceeding RUB 1 billion
Supporting the development and adoption of a regional law granting benefits to airlines based in a region
Supporting a telecommunications leader when confirming the right to regional investment incentives
Structuring
Proper transaction structuring or structuring of business in general is a guarantee of having a smooth operation without huge tax risks in the future. The same applies to annual tax audit of current structures, based on changes in law and the practice of its application.

Taxology lawyers will help to plan a transaction chain, build a group's structure, identify possible tax risks and potential both in M&A transactions and in any other transactions and activities, including those involving a foreign element.
We specialize primarily in tax disputes; therefore, when developing a tax structure, we initially provide for effective mechanisms to protect it in case of tax claims.
PROJECTS
Advising a major taxpayer during a cross-border restructuring, burdened by a requirement to keep the consolidated group of taxpayers
Restructuring a Russian agro-industrial holding company, including intellectual property ownership matters
Tax planning as part of a FMCG holding company's restructuring, allowing for about RUB 1 billion risk elimination
Structuring a number of asset acquisitions and creating a foreign development group's presence in Russia via individual enterprises
Development of an operational set-up for a development project with over RUB 8 billion investment
Tax
Audit
Assessing the tax risks of an asset acquired when making M&A transactions has become a mandatory procedure adopted in Russian and international practices.

Tax audits are also needed in the ordinary course of business, for example, when preparing for an upcoming field audit.

Taxology professionals, including lawyers, accountants and certified auditors, carry out an in-depth, comprehensive and realistic analysis of the company's tax accounting system and tax liabilities, particularly for the purpose of risk and overpayment identification.
Following the analysis results, Taxology professionals can develop and implement a set of measures aimed at reducing the identified risks before the tax audit by preparing a so-called defense file in the areas important for the client.
PROJECTS
Due diligence when buying a regional part of a large bookstore chain business
Tax due diligence in Yamalo-Nenets Autonomous Okrug gas assets acquisition by a major chemical company
Tax audit and supporting a refund of RUB 800 million tax overpayment as a result of an increased depreciation factor used at a producing company
Tax audit as part of a major regional Internet operator acquisition
Assessment of tax risks when acquiring a foreign trading network business in the Russian Federation
Supreme Court
Defense
A lost case is not the end of the world, but a good reason to use the last chance and be heard in the Supreme Court of the Russian Federation.

Taxology lawyers have a solid and successful experience in preparing tax dispute appeals to the Supreme Court of the Russian Federation, as well as representing taxpayers' interests in hearings.
Judgments with our involvement get on the most significant tax disputes reviews according to the Presidium of the Supreme Court of the Russian Federation and in view of the Federal Tax Service of Russia itself.
PROJECTS
Representing an energy company in the Supreme Court of the Russian Federation in a precedent-setting dispute over declarative VAT refund procedure
Representing a car dealer in the Supreme Court of the Russian Federation in a dispute over unjustified tax benefits in the presence of intermediaries in the transaction chain
Representing a regional trading company in the Supreme Court of the Russian Federation in a precedent-setting dispute over verifying that the prices in uncontrolled transactions are market ones
Representing a food producer in a precedent-setting dispute over reducing output VAT when paying rebates, which consolidated many years of controversial practice at the Supreme Court of the Russian Federation level
Representing an energy company's interests in the Supreme Court of the Russian Federation in a dispute over the deadline for appointing field reaudit when filing revised declarations