Andrei Sheptiy
Senior Associate
Andrei Sheptiy is a Senior Associate of the VERBA LEGAL Tax Practice.
Andrei focuses on advising Russian and foreign companies on Russian and global taxation for the purposes of raising tax effectiveness and minimising potential tax risks (various business matters, transaction structuring, attraction of foreign and domestic equity and debt financing, acquisition and disposal of assets, corporate restructuring, management and employee taxation, structuring of incentive and option programmes).
Andrei possesses large experience in preparing transaction and issue documents in the framework of M&A transactions and capital market access, and in conducting internal tax audits and pre-sale due diligence.
His job includes development of the most tax-efficient personal and corporate structures. Andrei is also much experienced in advising on taxation of operations with securities and financial instruments.
Andrei focuses on advising Russian and foreign companies on Russian and global taxation for the purposes of raising tax effectiveness and minimising potential tax risks (various business matters, transaction structuring, attraction of foreign and domestic equity and debt financing, acquisition and disposal of assets, corporate restructuring, management and employee taxation, structuring of incentive and option programmes).
Andrei possesses large experience in preparing transaction and issue documents in the framework of M&A transactions and capital market access, and in conducting internal tax audits and pre-sale due diligence.
His job includes development of the most tax-efficient personal and corporate structures. Andrei is also much experienced in advising on taxation of operations with securities and financial instruments.
He advises private clients on matters related to relocation, application of the deoffshorisation law, structuring of assets return to Russia, and tax planning for personal assets management and intra-jurisdiction transfer (including through CEIF, personal funds, and other structures).
Andrei took part in advising on many complicated and multi-dimensional tax disputes, and successfully provided legal support to clients during pre-inspection analysis, tax inspections, and on the pre-trial and trial stages of dispute resolution, including representation in the tax authorities and in courts.
Before joining VERBA LEGAL, Andrei worked with Ernst & Young and with the Tax Practice of Bryan Cave Leighton Paisner (ex. Goltsblat BLP), one of the world’s largest legal firms.
Education
Andrei graduated with honours from the Ural State Law University in 2019. He has a bachelor degree in international law, and a master degree in international tax law.
He is a post-graduate student, and is working on a PhD thesis on international taxation.
He is a post-graduate student, and is working on a PhD thesis on international taxation.
Academic Activity
Andrei is the founder and a permanent author of Telegram channel “Head of Tax” for tax professionals, with a 3.4 k audience.
Winner and awardee of many student competitions on Russian and international taxation as a participant and coach of the MSU and NRU HSE team.
Administers national Tax Live student competition.
Author of research works published in RSCI and HAC editions.
Visiting tax lecturer at RUDN, USLU, NRU HSE, and educational online platforms.
Winner and awardee of many student competitions on Russian and international taxation as a participant and coach of the MSU and NRU HSE team.
Administers national Tax Live student competition.
Author of research works published in RSCI and HAC editions.
Visiting tax lecturer at RUDN, USLU, NRU HSE, and educational online platforms.
Project Experience Highlights
TAX CONSULTING
Advised a Russian public online company on NASDAQ de-listing and transfer to the Russian jurisdiction via SAR, and took part in the preparation of the tax sections in the tender documents on buy-out and exchange of shares of public and institutional shareholders.
Advised on M&As and the accompanying restructuring, sorting out intra-group debts, and bearing in mind the corporate and counter-sanction restrictions for foreign companies selling their Russian businesses (including preparation of the tax sections of the transaction documents).
LTIP tax structuring for the Russian top management of a European public perfume company.
Advised a NYSE-listed US company on application of the look-through approach to payment of dividends subject to the LOB rules and the technical comments of the US Model Income Tax Convention.
Structured the group of a major Russian software developer to ensure confidentiality of ownership, streamline the historic structure, and retain the possibility of enjoying IT tax benefits.
Took part in tax due diligence of over 30 M&As of Russian and multi-national groups, identifying multi-million tax risks and reserves.
Provided tax advice for organisation of joint ventures (JV) and financing structures with shareholders/participants from friendly jurisdictions.
Advised a Russian member of a multi-national group on large-scale changes in the Russian TP rules and the effect on the client’s business (including secondary dividend adjustment, contents of the TP documents, safe price change limits in the new environment).
Made a tax analysis of corporate ownership restructuring for a Russian public company, with the use of CEIF and flexible-price options.
Advised HNWI on the tax aspects of relocation to foreign jurisdictions, and of assets return to Russia using the tax support measures.
TAX DISPUTES
Successfully advised a large development company at the pre-trial stage of a tax dispute related to recognition of interest expenses on cross-border project financing with claims for over 500 mln roubles.
Advised a precedent-setting Russian car dealer in a tax dispute relating to cross-border corporate pre-IPO restructuring with additional accrual of 2 bln roubles.
Prepared a successful defence file on the beneficial ownership aspect of dividend payments, which resulted in an episode with potential additional tax accrual of several hundred million roubles being removed from the inspection report.
Successfully advised a large regional importer of fruit in a tax dispute on imputation of income from fruit sales in connection with a price claim. In addition to the favourable outcome of the case, a position of importance was formed in regard to the obligation of the tax authorities to take into account the TP methods when applying Art. 54.1 of the Russian Tax Code (Case No. А45-25913/2023).
Successfully advised on a tax dispute, where a precedent of importance for other taxpayers was formed in regard to the general 3-year VAT deduction period applying also to advance deductions (Case No. А40-130974/23).
Support for a tax dispute of a Russian medical product distributor with the customs authority on refusal to apply the 10% VAT rate to the medical products imported into Russia.
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