Tax disputes

A tax authority claim, an additional assessment following a desk or field audit, a dispute over tax residency, penalties for a missed CFC notification — in every case the cost of a mistake is measured in additional tax, interest and penalties, and appeal deadlines are limited and are not restored automatically. We support tax disputes at every stage: from objections to an audit report to challenging a decision in court.

Context
Who is this for?
  • Business owners and senior executives who received an additional tax assessment following an audit.

  • Persons controlling a CFC who missed the notification deadline or are disputing an additional assessment.

  • Residents and non-residents whose tax status is disputed by the tax authority.

  • Companies that received a claim following a desk audit of a tax return.

Relevance
What problems are solved?
  • Additional assessments made without a genuine tax benefit or because of a counterparty's formal violations.

  • Missing the deadline to appeal a tax authority's report or decision.

  • Insufficient documentary support for a tax relief, deduction or residency status.

  • Double taxation where foreign assets and income are involved.

's services include
Assessing the prospects of challenging

a tax authority's report or decision

Preparing objections

to a tax audit report

Appealing tax authority decisions on desk and field audits

before the higher tax authority and in court

Protecting the interests of CFC controlling persons

on notification and assessment matters

Challenging tax residency status
Questions and answers
Participants in international and Russian professional rankings: Best Lawyers, Chambers, The Legal 500, Who Is Who Legal, World Tax, Leaders League, Forbes Legal Ranking, Kommersant, PRAVO‑300.
What should you do if the tax authority has made an additional assessment following an audit?
First, assess the prospects of an appeal and don't miss the deadline: one month for objections to the audit report and one month for an appeal to the higher tax authority once the decision is issued. Going to court is only possible after this mandatory pre-trial stage.
What is a CFC controlling person liable for if they miss the notification deadline?
A fine for failing to file the CFC notification and financial statements, plus the risk of an additional CFC profit-tax assessment if the threshold for undistributed profit is exceeded. Systematic violations can also carry criminal liability.
How does the tax authority determine an individual's tax residency?
By the number of days actually spent in Russia over 12 months (more than 183 days) and a range of other factors — center of vital interests, real estate, family, main source of income. Disputes most often arise when border-crossing records conflict with the taxpayer's position.
What happens if you don't pay the additional assessment while the dispute is ongoing?
Non-payment doesn't stop enforcement: the tax authority may debit the amount from your accounts. To suspend enforcement while the dispute is pending, you must separately apply for interim measures — filing the appeal or claim alone does not do this.
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Let us discuss your situation
Tell us about the circumstances of the dispute — we will suggest a strategy and assess the prospects before the work begins.
Schedule a consultation