Articles by Evgeny Timofeev



Legal Highlights: New Tax Environment: Will Courts Continue Mistreating Double Tax Treaties?

  • 19 November 13
  • Goltsblat BLP
A foreign investor operating in Russia through any form of corporate presence faces the need to make use of and rely on at least some international tax law concepts.

VAT on Bonuses: Is There a Way Out?

  • 17 December 12
  • Goltsblat BLP
It is now about three years ago that the Supreme Arbitration Court delivered its ruling in the Dirol Cadbury case hinting that bonuses payable to purchasers based on e.g. volume of sales were in effect nothing other than discounts applied retroactively, thus affecting the suppliers' sales for VAT purposes.

Key Russian Cases That Will Affect How You Manage Tax in 2012

  • 08 February 12
  • Goltsblat BLP

In 2011, five key court decisions from the Supreme Arbitration Court (SAC) shaped the way taxpayers do business in Russia. But their real influence will only be felt throughout 2012.

The Storm Is Coming: Make Your Move

  • 06 December 11
  • Goltsblat BLP
Federal case law has significantly changed the tax landscape quite recently. In Biryusa, the Presidium of the Supreme Arbitration Court (SAC) established that the statute of limitations for the offense of failure to pay tax (three years) actually starts counting from the beginning of the tax period coming after the one when the tax was due, and not after the one for which the tax had to be paid. This way the court changed its own case law previously established in 2005 in Urengoigazprom.

Russia to Apply Precedent-Based Law System

  • 08 December 09
  • Salans
Last week I was defending a client in a billion dollar tax dispute before the 9th Arbitration Appeal Court.

Are Tax-Free Dividends for Foreign Investors Possible?

As of this year, Russia alongside many countries with developed tax systems has a participation exemption enabling Russian (but not foreign) companies to receive dividends from Russian or foreign subsidiaries tax-free.

Thin Cap -- Still an Issue?

  • 11 December 07
  • Salans
As most countries do, Russia protects its right to tax in a variety of ways. One of them is designed to fight erosion of the tax base of Russian entities by paying excessive amounts of interest to related parties.

Thin Cap -- Still an Issue?

  • 11 December 07
  • Salans
As most countries do, Russia protects its right to tax in a variety of ways. One of them is designed to fight erosion of the tax base of Russian entities by paying excessive amounts of interest to related parties.

Withholding Tax: Pain in the Neck Over?

  • 13 March 07
  • Special for The Moscow Times
In practice, one out of three companies fails to obtain the necessary certificates before the payment date.

Presuming Taxpayer Bad Faith in Tax Disputes

  • 12 December 06
  • Salans
While tax authorities have to prove bad faith, the risk of conviction is formidable enough to force taxpayers to produce mountains of documents.