Mikhail BegunovMikhail Begunov

Mikhail Begunov

Member of the Chamber of Tax Consultants, Lawyer at the Moscow Chamber of Advocates
Industries

Manufacturing, IT business, Pharmaceuticals, Retail, Real Estate and Construction

V CARDV CARD
Biography

Managing Partner of Tax Compliance, professional "tax" lawyer.

He has more than 18 years of experience in the field of taxes and taxation. Before heading Tax Complaint, Mikhail worked in the structure of the Federal Tax Service, having worked his way up from specialist to head of department, as well as in a consulting company as one of the partners, where he supervised the tax direction.

Mikhail specializes in representing clients in complex tax disputes and assisting in conducting desk and field tax audits. With his assistance, a significant number of tax disputes were resolved in favor of clients even at the pre-trial stage.

He has considerable experience advising clients on a wide range of issues related to the application of tax legislation, as well as on the aging of tax statistics and forecasting of industry tax risks in the construction, retail and transport industries.

Mikhail's professionalism and the high level of projects implemented by him are recognized by key international and Russian legal ratings (Pravo-300, Kommersant, Best Lawyers), marking him among the best tax lawyers in the country.

Certified tax consultant. Member of the Chamber of Tax Consultants since 2007. Member of the Association of Lawyers of Russia.

Regular speaker of specialized tax conferences and author of articles and comments for business media.

Cases

Production
193 mln
Pre-court settlement of tax disputes

Claim of the tax authority on improper use of VAT credits was disputed.

Pharmaceuticals
343 mln
Pre-court settlement of tax disputes

Withdrawn claims of the tax authority against suppliers of raw materials for medicines

Retail
Successfully
Criminal defense of business for tax crimes

Represented a major supplier of shut-off and control valves in a criminal case brought under Article 199 of the Russian Criminal Code before the tax authorities' decision on the field audit.

Retail
Successfully
Court settlement of tax disputes

Representing a major distributor in court on the issue of interim measures and suspension of the tax authority's decision

transport
280 mln
Transfer pricing

Challenged the position of the tax authority on the audit of transfer pricing

Construction
7.5 mln
Pre-court settlement of tax disputes

Support of the client in appeal against the decision of the tax authority on the issue of bringing to responsibility for willful non-payment of taxes

Retail
23 mln
Currency regulation

The company's interests in the case of violation of currency legislation were protected in arbitration courts of three instances.

IT
Successfully
Tax support for IT-business

Checking the possibility of applying the tax incentives provided for in the IT maneuver

Construction
Successfully
Pre-court settlement of tax disputes

Support of the client in appealing to the Central Office of the Federal Tax Service of Russia against the decision of the tax authority on the issue of bringing to responsibility for willful non-payment of taxes

Construction
Successfully
Tax Audit

Successful tax audit to identify "problematic" counterparties

Retail
520 millions
Support of tax audits

Protecting the interests of the largest supplier of oil and gas equipment to domestic and global industry leaders.

IT
Successfully
Pre-court settlement of tax disputes

The decision of the field tax audit was reversed in the pre-trial procedure

Construction
50 mln
Pre-court settlement of tax disputes

It was proved that there was no affiliation with suppliers, and reality of subcontractors’ activities.

Pharmaceuticals
Successfully
Pre-court settlement of tax disputes

Preparation of a legal position confirming the reality of delivery of goods by the counterparty involved

Pharmaceuticals
Successfully
Court settlement of tax disputes

Judicial protection of the interests of a major pharmaceutical company in challenging the claims of transactions with "unfair" counterparties

Retail
Successfully
Support of tax audits

Support of tax control measures to confirm the reality of providing services by contractors

Retail
Successfully
Support of tax audits

Elimination of risks of reclassification of transaction with interdependent company-lender.

Retail
1 billion
Pre-court settlement of tax disputes

Preparation of a legal position to confirm the reality of the relationship with the disputed importers of goods

Construction
Successfully
Pre-court settlement of tax disputes

Preparation of a legal position confirming the reality of delivery of goods by a subcontractor

Construction
Successfully
Support of tax audits

Preparation of a legal position to confirm the reality of the relationship with subcontractors

Retail
Successfully
Tax support of transactions

Restructuring of business in order to apply exemption from VAT and insurance premiums

Construction
Successfully
refund

Support of VAT refund procedure

Construction
Successfully
Support of tax audits

transport
Successfully
Advising on the application of tax legislation

Analysis of tax risks in debt restructuring

transport
Successfully
Advising on the application of tax legislation

Retail
Successfully
Criminal defense of business for tax crimes

Represented a major distributor of perfumes and cosmetics in a tax dispute in arbitration court in a criminal case for tax evasion on the grounds of the crime under Part 2 Article 199 of the Criminal Code.

Construction
Successfully
Support in the framework of pre-test analysis

Construction
Successfully
Analysis of the system for interaction with counterparties

Analysis of the effectiveness of the taxpayer's internal control system for selecting and interacting with counterparties

Construction
Successfully
Health-check

Express - analysis of client's business activities for the presence of tax risks

Pharmaceuticals
Successfully
Advising on the application of tax legislation

Analysis of tax risks associated with the possible qualification of the nature of the Group's business (federal pharmacy chain) as a "split" business scheme

Construction
Successfully
refund

Confirmation of the validity of the application for VAT refund outside the three-year period

Retail
Successfully
Pre-court settlement of tax disputes

Confirmation of the absence of an unjustified tax benefit in the form of a surcharge on goods

Production
Successfully
Pre-court settlement of tax disputes

Support of the client in the framework of the appeal of the client on the issue of the legality of accounting exchange rate differences

IT
Successfully
Tax support for IT-business

Production
Successfully
Support in the framework of pre-test analysis

Assisting the client in preparing a legal position on the "splitting" of the business

transport
Successfully
Advising on the application of tax legislation

Advising the client on personal income taxation of individuals working outside the Russian Federation

Construction
Successfully
Tax monitoring

IT
Successfully
Support within the framework of obtaining the status of an accredited IT company

Production
Successfully
Tax monitoring

Development of a description of a comprehensive internal control system and requirements for automation of control procedures

Production
Successfully
Tax monitoring

Development of requirements for the functionality of an analytical data mart for the purposes of tax monitoring

Construction
70 mln
Support of tax audits

Support of a field audit of a construction company and preparation of a tax reconstruction calculation that allowed to reduce the amount of tax claims by half

Construction
580 million
Court settlement of tax disputes

Successful appeal of additional VAT charges in a tax reconstruction case

Construction
300 m
Tax-support

Analysis of tax risks related to the offsetting of counterclaims

Construction
Successfully
Support of disputes with tax authorities

Defending a construction company during a tax audit

IT
Successfully
Support within the framework of obtaining the status of an accredited IT company

Retail
Successfully
Advice on taxation of CFCs

Analysis of tax risks associated with CFC notification filing

Retail
Successfully
Tax-support

Analysis of tax risks for VAT and profit tax associated with the sale of products by the Client in case of its payment by purchasers with bonuses in full, as well as the order of registration of cash vouchers in this case

Construction
410 mln
Pre-court settlement of tax disputes

Defended a Russian company specializing in wholesale trade of equipment for mining and construction against tax claims under sec. 54.1 of the Russian Tax Code at the stage of objections to an addendum to a tax audit report.

Construction
Successfully
Support of individual tax control measures

Support of an international EPC-company within the framework of pre-trial tax control activities

Retail
1 billion
Tax-support

Analysis of risks in the realization of Russian business by "unfriendly" residents

IT
Successfully
Tax benefits and government support

Development of a resolution to the Ministry of Justice of the Russian Federation

Retail
Successfully
Tax-support

Analysis of tax risks associated with transactions with shares in the authorised capitals of the Companies.

Production
Successfully
Consulting in the UAE

Opening a corporate bank account in the UAE

IT
Successfully
Tax-support

Analysis of tax risks associated with the withdrawal of the IT function

Production
Successfully
Consulting in the UAE

Supporting the procedure of dismissal of an employee of a mainland - company in the UAE

energy
Successfully
Consulting in the UAE

Legal support of an acquisition of assets in India

Retail
102 million
Pre-court settlement of tax disputes

Preparing a legal position on royalty payments by a Russian organization to a foreign company

IT
87 million
Support of tax audits

Supporting an on-site tax audit of a major Russian bank

Construction
Successfully
Tax-support

Analysis of tax consequences associated with the acquisition of a part of a share in its own authorized capital by an organization

Construction
Successfully
Tax-support

Analysis of the possibility of using the simple partnership agreement structure in the construction of an apartment building

Retail
Successfully
Tax-support

Analysis of the possibility of applying the VAT exemption provided for catering establishments

Retail
Successfully
Tax-support

Analysis of tax risks associated with the application of a reduced VAT rate on the sale of certain goods

transport
Successfully
Tax support of transactions

Supporting intragroup debt restructuring in the context of sanctions restrictions

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