Russia

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Transfer pricing
Alarius Consulting

Alarius Consulting has a focus on tax consulting and transfer pricing matters; transfer pricing advisory brings in approximately 70% of its revenue. The team consists of one partner, two senior lawyers and five junior specialists. The key industries the firm is experienced in are retail, finance and insurance services, pharmaceuticals, trade and production of industrial equipment.

One of the firm’s largest cases was advising an international group entity on developing pricing methods and implementation, transfer pricing documentation, intra-group transfer pricing procedures and the practical implementation of such within 15 subsidiaries with revenue greater than €1 billion.

Althaus Group

Althaus Group is a Russian advisory firm, part of WTS Global – the global network group of independent tax advisors. It employs more than 150 professionals in finance, tax, law, evaluation and engineering. Its tax department is divided into three parts: corporate tax, headed by director Maria Vershinina; tax M&A, headed by director Vladimire Shchedrov; and a private client tax practice, headed by managing partner Sergey Gerasimov working with Maxim Kluchnikov and Alexander Neponayshiy, who are both partners. Althaus Group has worked with large companies such as Gazprom, Rosneft, Vnesheconombank, Rosgeo and more. 

The team assisted Leoni Group Russia (a supplier of products, solutions and services for energy and data management) on preparing a transfer pricing local file complying with the new OECD BEPS directive. It carried out a benchmark study, prepared a functional analysis and analysed prices within the intra-group transactions with the market level. The team also advised a large company on its petrochemical complex in Russia. This involved a transfer pricing analysis of the company’s intergroup transaction prices compared to market level prices. It provided the client with transfer pricing documentation consisting of 10 separate documents relevant to the financial year covering, but not limited to, production and supply of heat energy, electric energy on the wholesale electricity supply market, storage of petroleum products, leasing of production facilities/equipment and administrative premises.

Baker McKenzie

Baker Mckenzie offers a comprehensive range of tax and transfer pricing services. It has more than 660 tax lawyers in 77 offices located in 47 countries, allowing for the structuring of cross-border transactions across multiple jurisdictions.

The team advised a group company, provider of integrated technology-driven solutions and water process applications, on preparing its transfer pricing documentation following a global change in the transfer pricing model of distribution operations. The case involved preparation of the Russian transfer pricing documentation for diverse intercompany transactions of the domestic subsidiary companies, in addition to the intercompany supply of goods, IP licensing, and supplying of intercompany services. This required effective, clear communication between Baker Mckenzie Moscow and the US transfer pricing teams.

BDO Unicon

BDO Unicon is an audit and consulting group with more than 1,500 employees in its network of offices in Moscow, St Petersburg and other cities in Russia. Sergey Chelyshkov and Vitaly Ivanenko, both partners, lead the tax department.

The team has advised various clients, from the beverage industry to telecommunications, with the preparation of transfer pricing documentation, such as drafting and updating documentation on controlled transactions. The recent cases relating to transfer pricing documentation align with the recent OECD BEPS directive.

Bryan Cave Leighton Paisner

The Bryan Cave Leighton Paisner tax team is made up of 19 associates and two partners. More than half of its staff have more than 11 years of experience. The firm was created this year when US law firm Bryan Cave merged with Berwin Leighton Paisner – with its Russian practice Goltsblat BLP. The firm offers clients services from 32 offices in 11 countries and a platform of around 1,600 lawyers. Evgeny Timofeev, who has 26 years’ experience in taxation, leads the tax team, which offers full tax legal services. 

The firm is advising a client on the restructuring of group companies to build a new corporate structure. The tax team delineated a roadmap for the client group companies restructuring in respect to the financial standing of, and the tax risk effective for, each company. It also assisted the client with large liquidation—tax free—of controlled foreign corporations.

Cliff Legal Service Law Firm

Cliff Legal Service Law Firm has been providing tax legal services for more than 20 years to Russian and foreign companies. The firm specialises in financial and tax restructuring cases and has its own tool that allows the implementing of proposed models in practice.

Deloitte

Deloitte advises clients in tax legal matters covering all tax areas. The firm has offices in Moscow, St Petersburg, Ekaterinburg, Ufa, Novosibirsk and Yuzhno-Sakhalinsk. It specialises in Outsourcing and tax compliance, transfer pricing, tax dispute resolution and private client services. Svetlana Meyer is the managing partner of tax legal.

The team advised a client on automating and structuring routine business processes reporting developed by Deloitte CIS. The process required close attention and was time consuming because of the due care applied to prevent prone human error factors. The process included – but was not limited to – the following: investigating the clients possibility applying for controlled foreign companies (CFCs) tax exemption and determining the method of profit calculation for the client’s CFCs aligned with the law.

Dentons

Dentons has strengthened its tax department with the recruitment of 20 tax experts since November 2017, bolstering its transfer pricing department with the recruitment of three expert transfer pricing practitioners from KPMG and EY. The tax department is comprised of 34 experts working out of offices in Moscow and St Petersburg. There are lawyers, finance specialists, economists and accountants in the tax department. Some of the clients it advises are Amazon, Nestlé, Volkswagen, Sberbank, Dyson and more. 

Denton’s transfer pricing team advised a client on determining its arm’s length price of shares to agree as security for an affiliate’s loan regarding the group’s ownership and financial restructuring.

DLA Piper Rus

Ruslan Vasutin, working from St Petersburg, and Igor Venediktov, working from Moscow, are the two partners co-heading the tax team for DLA Piper Rus. They both have more than 20 years’ experience in tax. The practice provides a ‘one-stop shop’ advisory. Ruslan Vasutin and Elena Mikhailovskaya, both partners, lead the transfer pricing team, which includes two managing associates who have successfully advised on sizeable and complex transfer pricing cases. 

The transfer pricing team advised a large pharmaceutical firm on preparing transfer pricing documentation in compliance with Russian transfer pricing rules. The advisers carried out the relevant transfer pricing study on the key intra-group transactions for the audit period, and helped establish a suitable strategy to manage transfer pricing matters in Russia.

EY

The EMEIA Tax Center at EY is organised as a supranational entity covering the entire Europe, Middle East, India and Africa (EMEIA) region, with its Intercompany Effectiveness and operational transfer pricing practice serving clients’ needs across all jurisdictions.

Led by Oslo-based partner Sveinung Baumann-Larsen, it brings together multi-disciplinary experience and resources focused on IT, accounting, and tax from the entire region in its work. This work covers some of the leading global companies in their respective fields and includes those involved in retail and consumer products, energy and pharmaceuticals, to name but a few.

FBK Legal

FBK Legal, a Russian audit and consulting firm, is part of FBK Company. FBK Legal is a bar association established in 2012 as a spin-off from FBK’s tax and legal department. The tax team offers diverse tax legal services such as consulting, planning, disputes, due diligence and transfer pricing services. Nadezhda Orlova is the managing partner and Lioubov Staroverova is the transfer pricing partner.

The firm’s transfer pricing team assisted a large multinational client in the oil and gas industry in preparing transfer pricing documentation for its intra-group transaction. It carried out an in-depth analysis of any possible inconsistency with the transfer pricing rules during the clients restructuring and merger of one the group’s entities.

FinExpertiza

FinExpertiza’s tax department is experienced in providing tax legal services in industries such as oil and gas, transport, retail and wholesale, finance, construction, electricity and machine construction. The key tax advice areas offered by the tax team are corporate, indirect tax, disputes, transactional tax, transfer pricing, M&A, real estate and construction. In addition, it offers a hotline for its clients to get online support on their tax issues.  

The team has assisted various Russian firms on developing methodological documentation for tax control of their controlled transactions. The documentation involved delineating the type of individual entities involved in the controlled transactions to understand the features of the pricing process, analysis of the controlled companies structure and activity, determining the price methodology concerning taxation and defining the market prices gaps and interval profitability.

KPMG

KPMG has been offering tax advisory in Russia for more than 27 years with nine offices in Moscow, St Petersburg and other regions. It has more than 500 dedicated professionals working in Russia. The transfer pricing department consists of 70 professionals. In 2017 it launched its transfer pricing practice in Novosibirsk and bolstered its capability by hiring two directors. The key sectors it is involved in are oil and gas, construction, chemicals, consumer goods and heavy industry, among many others. 

The team assisted VimpeCom—the third-largest wireless and second-largest telecoms operator in Russia—on preparing transfer pricing documentation concerning its associated transactions with companies in its group. The total value of the intragroup transaction between FY 2015-2016 was estimated at $1 billion. Some of the work involved was to determine approaches to applying transfer pricing methods suitable for the client’s business and complying with Russian transfer pricing regulation, and to work out a methodology and application to calculate transfer pricing risks in the future for related transactions.

Mazars

Mazars has been providing its clients tax legal advice in all tax areas for eight years in Russia. The tax practice initially offered advice in compliance, income tax, audit support, transfer pricing compliance and tax due diligence. It has since expanded to offer corporate tax and organisational restructuring from 2016, working with Mazars’s legal team. The tax team has experience in industries such as consumer goods, machinery production, professional services, IT, pharmaceuticals and financial services. It also has specialists in oil and gas, metals and mining. 

Alexander Simonov leads the transfer pricing team, which was formed in 2012. It advises on transfer pricing compliance, documentation, developing policies, risk assessment and more.

The transfer pricing team assisted an owner of a shopping centre on calculating the range of its profitability. Because there was shortage of initial data from the client, the transfer pricing team proposed to change the sample criteria and add other criteria that would be consistent with the client’s transfer pricing policy and the financial year concerned in the matter, and constructed the necessary market range.

PwC

PwC has a specialist transfer pricing team with 120 years’ combined experience. The accounting firm’s global transfer pricing team consists of 300 partners, and more than 3,100 fully dedicated transfer pricing professionals in more than 90 countries. It offers its clients complete advice on transfer pricing matters such as documentation, APAs, Country-by-Country Reporting (CbCR), etc. The firm has been innovative in developing strategies for clients to reduce the transfer pricing challenges from authorities and audits, and helps clients solve transfer pricing queries before the litigation stage.

PwC advised UK Gruppa GAZ, a large Russian automotive manufacturing group, assisting with developing a methodology for preparing CbCR for 2016. The transfer pricing team helped the client establish the requirement of CbCR legislation in various jurisdictions connected to the client’s group companies, evaluated the possible tax risks and sanctions in case of any inconsistency with the legislation and prepared and filed a CbCR for 2016 with the Russian tax authority.

Shapovalov Petrov Law Firm

Shapovalov Petrov Law Firm offers a full range of tax legal advice. This includes litigation, transfer pricing, due diligence, M&A tax and more. It has strength in the media, mining, transportation and logistics industries.

The team assisted Panalpina with a benchmark study and the preparation of transfer pricing documentation regarding royalty payments. Kirill Petrov and Leonid Artemiev worked on this case.

Taxology

Taxology is an independent law firm focusing exclusively on tax legal matters. It provides full tax advice in areas such as controversy, M&A, transfer pricing and more. The team has acquired multinational clients such as Alpha Bank and Continental Tires among others. 

The team advised Don Tabak – the Russian subsidiary of Japan Tobacco International – on preparing transfer pricing documentation for the buying and selling of tobacco-related products, rent of production premises and leasing its equipment. It also assisted in assessing the financial calculations of the market price.