Tax Practice

Assistance with tax audits and disputes.

Developing a defense or dispute resolution strategy.

Attracting the best and most effective local consultants and tax attorneys in any jurisdiction. Setting tasks, managing the budget, and monitoring quality of work.

Initiating tax disputes to protect the Client's rights, or supporting the Client when disputes are initiated by tax authorities across all jurisdictions.

Identifying and analyzing tax risks, assessing them, and providing recommendations for elimination or mitigation.

Developing and preparing a "defense file" containing legal and technical positions regarding high-risk transactions.

Advising on opportunities to reduce tax risks.

Assisting in obtaining official clarifications from tax authorities.

Supporting tax audits across all jurisdictions.

Analyzing requests and demands received from tax authorities and preparing reasoned responses.

Assisting in selecting a team of local tax attorneys.

Providing recommendations on the list of required documents, as well as the content and format of explanations submitted to tax authorities.

Verifying the accuracy and proper execution of document packages prepared for submission to tax authorities.

Assessing the chances of appealing tax audit results through established procedures.

Assisting in appealing tax audit results through both pre-trial and judicial processes.

Analyzing tax audit acts and decisions, and evaluating the evidence gathered by inspectors.

Assisting in preparing written objections to tax audit acts or decisions.

Assisting in preparing appeals to higher tax authorities.

Developing a conduct strategy during litigation.

Preparing court submissions, including applications to invalidate tax authority decisions or actions (omissions) of tax officials, applications for interim measures (if necessary), and other procedural documents (motions, explanations, responses, etc.).

Developing strategy, providing support, and conducting negotiations with tax authorities to reach settlement agreements.

Protecting shareholders and top management from the collection of tax liabilities under secondary (subsidiary) liability. For example, in Russia, a claim for subsidiary liability can be brought against a participant, shareholder, or top manager of an organization (Persons Controlling the Debtor) within a 10-year period.

Assisting in developing a defense strategy and minimizing risks.

Restructuring outstanding tax liabilities. Assisting with restructuring processes (obtaining deferrals, installments, or replacing security measures).

Mitigating the risks of bankruptcy and business loss.

Providing assistance at the stage of enforcing judicial acts, including enforcement proceedings.