Юридическая фирма VERBA LEGAL

Selected Experience

Ratings and Awards

Academic and educational activities

News and publications

Evgeniya Zainchukovskaya

Counsel, Head of Tax and Customs Law Practice

Tax Advisory and Litigation Private Clients Customs Law and Foreign Economic Activity Currency Regulation

Phone

+7 (495) 374-74-03

evgeniia.zainchukovskaia@verba.legal

Contacts

Download vCard

Languages

Russian, English

Evgeniya specializes in advising individuals and legal entities on tax planning and asset ownership structuring. Evgeniya has managed complex international projects requiring in-depth knowledge of foreign countries' national tax legislation, coordination with local consultants, and direct interaction with foreign tax authorities.

Evgeniya managed projects involving tax due diligence, including M&A transactions, for companies with business valuations exceeding RUB 10 billion.

Furthermore, Evgenia successfully represents taxpayers in tax disputes, particularly regarding the receipt of unjustified tax benefits and the tax accounting of real estate.

Selected Experience

Tax Consulting

Evgenia advised:

a Russian company, general partner of the Chinese concern Great Wall Motors in Russia, on excise and recycling fees for M1 category electric vehicles where the internal combustion engine does not affect the transmission, as well as on undue fiscal advantages when importing electric vehicles from China via Belarus and Kyrgyzstan into Russia by individuals;

the creation and registration of an IT company in the High-Tech Park of Kyrgyzstan, including calculation of tax efficiency of operations taking into account applicable benefits and receipt of royalties from the Netherlands;

a Russian company organising observational medical studies on applying Clause 68 of Article 217 of the Russian Tax Code to cashback paid by the electronic platform operator to patients to improve real-world clinical practice studies;

a subsidiary of the world leader in aesthetic dentistry on VAT exemption for importing dental medical devices with accessories from Switzerland to Russia when supplied separately;

an Italian pharmaceutical company with a presence in Russia on tax implications and risks of disposing of a research laboratory under "Share Deal" and "Asset Deal" models;

a public food company in analysing Russian tax legislation for provisions allowing marketplaces fiscal advantages over retail store owners;

the procedure for creating a private foundation in Russia to consolidate the founder's assets, optimise management and efficiently pass wealth to future generations;

Russia's first and only fibre-optic cable manufacturer on tax structuring of a transaction where a US seller disposes of 100% shares in a Russian company and restructures intra-group debt;

a cloud video surveillance system developer on tax aspects of changing ownership structure of Russian and US operating companies via SPV creation, various reorganisations, redomiciliation of the holding company to the SAR and other matters;

a closed-end investment mutual fund management company on taxation of payments to Russian and foreign individuals and legal entities;

a Russian company on tax aspects of creating an investment fund, exploring structuring options via SPV, convertible loan agreements and closed-end investment mutual funds;

a leading multimodal digital forwarder on restructuring intra-group loans with a foreign element.

Tax Due Diligence Sections

Evgenia supported:

tax due diligence of a Russian company providing hotel services and resident of the Crimea SEZ in an M&A transaction;

tax due diligence of a Russian company with state IT accreditation on eligibility for IT tax benefits under Clause 1.15 of Article 284 of the Russian Tax Code;

tax due diligence of a group of companies in residential and non-residential construction to identify tax reserves for improving tax efficiency;

tax due diligence of an international transport forwarder company in an M&A transaction;

tax due diligence of Russia's largest agricultural holding to identify assets erroneously classified as immovable and included in the corporate property tax base.

Tax Disputes

Evgenia supported:

a tax dispute of a Russian company mining moulding sands compliant with GOST 2138-91 "Moulding Sands. General Specifications" on correct determination of the mineral extraction tax object;

a tax dispute of a Russian company mining limestone for soda production on correct determination of the mineral extraction tax object;

a tax dispute of a Russian company developing an apatite-nepheline ore deposit on correct determination of the mineral extraction tax base based on calculated value of extracted minerals;

a dispute of a Russian medical devices distributor with customs authorities on refusal to apply 10% VAT rate for importing medical devices into Russia;

a tax dispute of a construction company on undue tax benefit exceeding RUB 500 million;

control measures in the tax authority and Russia's Investigative Committee during a field tax audit of a millionaire blogger;

a tax dispute of Russia's largest agricultural holding on classifying assets as movable or immovable for corporate property tax purposes.

Customs Law

Evgenia advised:

a Russian pharmaceutical company on assigning and changing HS code for active pharmaceutical ingredient (API) upon import into Russia, including assessment of additional import duty risks and preparation of a minimisation strategy;

a Russian participant in international transport on applying 0% VAT rate and zero import customs duty rate for importing seagoing vessels;

several Russian pharmaceutical companies on classifying cosmetology and dental medical devices under EAEU HS codes, assessing reclassification risks by customs and preparing recommendations to mitigate them;

a transnational consumer goods manufacturer on customs authorities' measures to protect intellectual property rights;

a pharmaceutical company on the legality of additional import duty at 35% due to untimely submission of certificate of origin.

achievements

Ratings and Awards

Evgenia is endorsed by Russian ratings, including: Pravo-300, Kommersant, Rossiyskaya Gazeta.

Pravo-300 in the nominations: Tax Consulting and Disputes (Consulting: High Market), Tax Consulting and Disputes (Disputes), Foreign Trade/Customs Law and Currency Regulation (Customs Law)

Kommersant in the nominations: Taxation: Tax Disputes, Taxation: Consulting, Foreign Trade

Rossiyskaya Gazeta in the nominations: Taxes, Private Equity and Investments

Academic and educational activities

Evgenia is a guest lecturer at Russian universities and an author of scientific publications recommended by the Higher Attestation Commission at the Ministry of Education and Science, focusing on the protection of top management from subsidiary liability for the tax debts of organizations.

Evgenia has developed a continuing education course in tax law for the Moscow Digital School platform and manages a Telegram channel on the topic with an audience of over 2,500 people.

what's new

News and publications

23 / 10 / 25

VERBA LEGAL Advises on Acquisition of Manufacturing Facility from a Rosnano Structure

The VERBA LEGAL team has successfully completed comprehensive legal support for the acquisition of 100% of the shares in Novamedica Innotech LLC — a manufacturing facility and research center previously owned by the pharmaceutical company Novamedica LLC.

#press release

25 / 09 / 25

Unseen Tax Aspects of M&A: Tax Considerations in Corporate Procedures

The VERBA LEGAL Tax Advisory and Disputes practice team, led by Practice Head Evgeniya Zainchukovskaya and Senior Lawyer Andrey Shepty, concludes its series of publications on the tax intricacies involved in M&A deals and corporate restructurings on the Telegram channel Head of Tax.

#legal alerts

02 / 09 / 25

Non-Obvious Tax Aspects of M&A: Contributions to Property