Юридическая фирма VERBA LEGAL

general information

Selected Experience

Ratings and Awards

news and publications

Andrey Sheptiy

Senior Associate

Tax Advisory and Litigation Currency Regulation

Phone

+7 (495) 374-74-03

andrey.sheptiy@verba.legal

Contacts

Download vCard

Languages

Russian, English

Andrey specialises in advising Russian and foreign companies on Russian and international taxation to enhance tax efficiency and minimise potential tax risks (various business activity issues, transaction structuring, attracting foreign and domestic equity and debt financing, asset acquisition and sale, corporate restructurings, employee and management taxation issues, structuring incentive and option programmes).

Andrey has accumulated significant experience in preparing transactional and issuance documentation for M&A deals and capital market entries, as well as conducting internal tax audits and pre-sale due diligence.

His work includes developing tax-optimal personal and corporate structures. Andrey also has extensive experience advising on taxation of securities and financial instruments operations.

Andrey advises private clients on issues related to relocation, application of de-offshorisation legislation, structuring asset repatriation to Russia, and tax planning in managing personal assets and transferring them between jurisdictions (including using ZPIF, private foundations, and other structures).

Andrey has participated in supporting a number of complex and multifaceted tax disputes and has successful experience in legal support of clients during pre-audit analysis, tax audits, as well as resolving disputes at pre-court and court stages, including representation in tax authorities and courts.

Selected Experience

TAX CONSULTING

Andrey advised:

a public Russian online company on delisting from NASDAQ and transitioning to Russian jurisdiction via SPAC, including the tax part of tender documentation for share buyback and exchange;

M&A deals and restructurings taking into account corporate and sanctions restrictions in the sale of Russian business by foreign companies, including development of tax documentation for transactions;

a European public perfume company on structuring LTIP for Russian top management;

a US company listed on NYSE on applying the "look-through approach" for dividend payments taking into account LOB rules and US Model Tax Convention provisions;

Russia's largest software developer on group structuring: ensuring ownership confidentiality, structure optimisation, and preservation of tax benefits for IT companies;

more than 30 tax due diligence reviews in M&A deals of Russian and international groups, identifying significant tax risks and reserves;

creation of joint ventures and new financing structures with shareholders from friendly jurisdictions;

a Russian multinational group company on changing TP rules in Russia, including adjustments to dividends, documentation content, and safe harbour pricing range;

a public Russian company on tax analysis of ownership restructuring using ZPIF and options with "flexible" pricing;

an HNWI on relocation abroad and repatriation of assets to Russia using tax support measures.

TAX DISPUTES

Andrey advised:

a major development company in a pre-court tax dispute on deducting interest expenses on cross-border financing exceeding RUB 500 million;

a Russian car dealer in a precedent-setting tax dispute related to cross-border pre-IPO restructuring, with claims of RUB 2 billion;

preparation of a "defense file" on thin cap issue for dividend payments, enabling avoidance of potential additional assessments in hundreds of millions of rubles;

a regional fruit importer company in a dispute on recognising income from sales, resulting in formation of a judicial position on applying TP methods under Article 54.1 of the Tax Code of the RF (case No. A45-25913/2023);

a tax dispute forming an important precedent on extending the general 3-year VAT deduction period to advance payments (case No. A40-130974/23);

a Russian distributor of medical devices in a dispute with customs authorities on the right to 10% VAT rate for imported products.

achievements

Ratings and Awards

In 2023, Evgenia was recognized in the top tier (the most "top-notch" specialists in the relevant practice area) in the "Tax" category of the Russian Newspaper's lawyer rating.