VERBA LEGAL

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Selected Experience

Ratings and Awards

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Andrey Sheptiy

Senior Associate

Tax Advisory and Litigation Currency Regulation

Phone

+7 (495) 374-74-03

andrey.sheptiy@verba.legal

Contacts

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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:

one of Russia’s largest gold mining companies on tax matters in connection with the restructuring of debt exceeding RUB 20 billion;

a leading leasing company on the tax aspects of restructuring its railway wagon fleet through a sale-and-leaseback arrangement;

T-Bank on the regulatory framework for an online aggregator for searching and arranging medical services and purchasing medicines, including the potential integration of AI-based solutions;

a leading leasing company focused on the agricultural sector on the tax implications and risks of debt restructuring and changes to its corporate structure;

an international mineral water producer on the tax structuring of the transfer of its holding structure from Cyprus to Russia;

the IT division of Russia’s largest retailer on the restructuring of its group of companies to preserve eligibility for tax incentives available to IT companies;

Russia’s leading cybersecurity company on the availability of a VAT exemption for software licensed under a Software-as-a-Service (SaaS) model;

a leading genetic testing laboratory on the restructuring of its group of companies to qualify for the corporate profit tax relief available to medical organisations;

a major Russian oilfield services company on the allocation, for tax purposes, of head office expenses incurred in the UAE to its Russian permanent establishment;

a private investment company headquartered in Luxembourg on the tax structuring of the transfer of assets from a Luxembourg fund to a Russian personal foundation.

Tax Disputes

Andrey advised:

a major fintech platform during a tax audit involving the tax authorities’ challenge to expenses incurred in acquiring software from a related group company;

a company belonging to an international pharmaceutical group in a dispute with the customs authorities concerning the lawfulness of applying the 10% VAT rate to the importation into Russia of intradermal gel implants;

one of Russia’s largest advertising groups in connection with tax claims exceeding RUB 1.5 billion under Article 54.1 of the Russian Tax Code;

a leading Russian freight company in a tax dispute concerning the deductibility of interest expenses under a debt push-down structure implemented as part of an M&A transaction;

one of the largest Russian distributors of premium automotive brands in a RUB 2 billion tax dispute concerning the calculation of VAT on the margin between purchase and resale prices;

a major fintech platform during a tax audit involving the tax authorities’ challenge to expenses incurred in acquiring software from a related group company;

a group of companies specialising in the development of efficient transport solutions for businesses in a dispute with the tax authorities concerning the eligibility of companies resident in Territories of Advanced Development (TADs) for the reduced social security contribution rate of 7.6%;

one of Russia’s largest steel products suppliers in a tax dispute under Article 54.1 of the Russian Tax Code;

a European pharmaceutical company in a dispute with the customs authorities concerning additional import VAT and customs duties assessed on the importation into Russia of an active pharmaceutical ingredient (API) used in the manufacture of medicinal products;

the largest aircraft tyre manufacturing plant in a tax dispute involving the tax authorities’ challenge to rental expenses.

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.