Tax Law

Tax Disputs
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.
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.
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.
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.
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.
Tax Benefits
Despite the trend set by the state towards the reduction of tax benefits, the possibilities for their use are still quite wide.

Benefits can be provided both at the federal and regional levels. Investment Tax Deductions, Regional Investment Projects, IPPA, Special Economic Zones, Priority Social and Economic Development Areas – the procedure for obtaining and using these is often seriously confused, and in most cases, the right to a benefit is conditional on the conclusion of special agreements with state bodies.

Negotiating and obtaining tax reliefs is a process that requires a significant amount of time and a professional approach in preparing the justification, financial models, structuring investments, formulating the tax reliefs and the contractual conditions for obtaining them.

Taxology lawyers have successful experience in obtaining and applying tax reliefs in different regions of Russia and at the federal level, as well as their subsequent pre-trial and judicial protection in the event of a tax dispute.

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.
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.
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.