tax - Ivanyan and Partners
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Resolving typical and unconventional tax issues

We advise corporate and private clients on all matters of tax planning strategy and tactics, both in Russia and abroad. Experience in managing big projects in various jurisdictions and partnerships with the best foreign tax advisors allow us to offer fully integrated business solutions that work efficiently on a global scale. The main areas of our work: tax structuring of Russian and cross-border M&A transactions, wealth planning and management for HNWI / UHNWIs, and tax disputes with a strong emphasis on pre-trial settlement.


Advised Xella, a big international producer of building and insulation materials, on implementing a new global transfer pricing policy. Matter value: €100 k+ (2020)

Advised a local Russian manufacturer of dairy products on tax matters concerning forming a joint venture with a global major in the food industry. Joint venture value: €25 m (2019-2020)

Advised one of the world’s biggest international construction companies on significant compensation for VAT surcharges in the context of a $590-m project for construction of an LNG-production facility in western Siberia (2018)

Representing the interests of the Russian subsidiary of Fels, Europe’s leading supplier of lime, in a precedent-setting tax dispute related to the tax treatment of a debt to equity swap under dept restructuring. Matter value: ₽300 m ($5 m) (2017-2018)

Represented a Russian distribution company, a subsidiary of a global spirits producer, in (i) a tax dispute related to tax deductibility (as well as VAT deduction) of various promotional fees to retailers, and (ii) a court dispute with tax authorities which claimed to be charged additional income tax and VAT. Matter values: (i) ₽500 m ($8.5 m) (2016-2017); (ii) ₽60 m+ ($1 m+) (2016-2017)

Represented Aquanika, a Russian drinking water producer, in a tax dispute related to appealing tax audit results. Matter value: ₽100 m ($1.6 m+) (2016-2017)

Advised a Russian business aviation company on a complex investment restructuring project in connection with the exit of one of the investors, a major airport operator. Matter value: $16.6 m (2017-present)

Advised a Russian subsidiary of the CRH group, a big international supplier of building materials, on the tax implications of using the group’s global trademark in Russia and settling a turnover-based royalty for it (2018)

Tax structuring as part of all-around support for a multi-stage and multi-jurisdictional corporate restructuring of a leading Russian investment group in the context of its deoffshorisation. Matter value: $2bn+ (2015-2016)