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
Claim of the tax authority on improper use of VAT credits was disputed.
Withdrawn claims of the tax authority against suppliers of raw materials for medicines
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.
Representing a major distributor in court on the issue of interim measures and suspension of the tax authority's decision
Challenged the position of the tax authority on the audit of transfer pricing
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
The company's interests in the case of violation of currency legislation were protected in arbitration courts of three instances.
Checking the possibility of applying the tax incentives provided for in the IT maneuver
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
Successful tax audit to identify "problematic" counterparties
Protecting the interests of the largest supplier of oil and gas equipment to domestic and global industry leaders.
The decision of the field tax audit was reversed in the pre-trial procedure
It was proved that there was no affiliation with suppliers, and reality of subcontractors’ activities.
Preparation of a legal position confirming the reality of delivery of goods by the counterparty involved
Judicial protection of the interests of a major pharmaceutical company in challenging the claims of transactions with "unfair" counterparties
Support of tax control measures to confirm the reality of providing services by contractors
Elimination of risks of reclassification of transaction with interdependent company-lender.
Preparation of a legal position to confirm the reality of the relationship with the disputed importers of goods
Preparation of a legal position confirming the reality of delivery of goods by a subcontractor
Preparation of a legal position to confirm the reality of the relationship with subcontractors
Restructuring of business in order to apply exemption from VAT and insurance premiums
Support of VAT refund procedure
Analysis of tax risks in debt restructuring
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.
Analysis of the effectiveness of the taxpayer's internal control system for selecting and interacting with counterparties
Express - analysis of client's business activities for the presence of tax risks
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
Confirmation of the validity of the application for VAT refund outside the three-year period
Confirmation of the absence of an unjustified tax benefit in the form of a surcharge on goods
Support of the client in the framework of the appeal of the client on the issue of the legality of accounting exchange rate differences
Assisting the client in preparing a legal position on the "splitting" of the business
Advising the client on personal income taxation of individuals working outside the Russian Federation
Development of a description of a comprehensive internal control system and requirements for automation of control procedures
Development of requirements for the functionality of an analytical data mart for the purposes of tax monitoring
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
Successful appeal of additional VAT charges in a tax reconstruction case
Analysis of tax risks related to the offsetting of counterclaims
Defending a construction company during a tax audit
Analysis of tax risks associated with CFC notification filing
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
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.
Support of an international EPC-company within the framework of pre-trial tax control activities
Analysis of risks in the realization of Russian business by "unfriendly" residents
Development of a resolution to the Ministry of Justice of the Russian Federation
Analysis of tax risks associated with transactions with shares in the authorised capitals of the Companies.
Opening a corporate bank account in the UAE
Analysis of tax risks associated with the withdrawal of the IT function
Supporting the procedure of dismissal of an employee of a mainland - company in the UAE
Legal support of an acquisition of assets in India
Preparing a legal position on royalty payments by a Russian organization to a foreign company
Supporting an on-site tax audit of a major Russian bank
Analysis of tax consequences associated with the acquisition of a part of a share in its own authorized capital by an organization
Analysis of the possibility of using the simple partnership agreement structure in the construction of an apartment building
Analysis of the possibility of applying the VAT exemption provided for catering establishments
Analysis of tax risks associated with the application of a reduced VAT rate on the sale of certain goods
Supporting intragroup debt restructuring in the context of sanctions restrictions
