Senior Associate
What she specialises in
Tatyana specialises in tax law, with an emphasis on international tax law. She provides advisory services to Russian and foreign clients in relation to various aspects of international taxation (e.g. in relation to taxing income generated by sources in the Russian Federation, implementing double tax treaties, and setting up permanent establishments). Tatyana’s expertise also includes advising on the implementation of so-called ‘deoffshorisation’ changes in tax law – for instance, rules for controlled foreign companies and concerning legal entities’ tax residence.
Her main achievements
Tatyana’s major projects include, among others:
•estimating the profit of over 40 controlled foreign companies (CFCs) of a major energy holding company, as well as evaluating whether the holding company had a right to a tax exemption for the profit of these CFCs;
•developing guidelines for calculating CFCs’ financial figures according to the rules established by the Russian Tax Code and comments on the list of documents required to confirm the calculation of CFCs’ profit and to apply exemptions;
•preparing road maps of business processes aimed at ensuring compliance with the CFC legislation and the rules used to determine the actual recipient (beneficial owner) of income;
•calculating the tax burden and assessing the tax risks of various options for restructuring the group of companies owned by a major Russian investment holding (the restructuring was aimed at transferring an asset, which was part of the holding structure, under the beneficiary’s direct ownership): devising the best possible restructuring scenario based on the rules for CFCs, and dealing with issues that related to transfer pricing, tax residence of legal entities, and the concept of an unjustified tax benefit, before drafting recommendations to mitigate tax risks;
•optimising a personal structure of ownership in relation to profitable assets for an individual (a Russian tax resident and resident for currency control purposes), taking into account the tax and other circumstances arising in more than five jurisdictions.
Tatyana was also involved in providing support in tax audits (including in courts) in relation to implementing the concept of an actual recipient (beneficial owner) of income, the provisions of double tax treaties, the OECD model convention and commentaries to it.
Her major clients
Gazprom Export, ONEXIM, Veles Capital, SDM Bank, Tele2.
What they say
“The legal opinions are always very well written and understandable even to people who don’t know anything about tax.” (Chambers Europe)
Pepeliaev Group
Russia
Email: t.pavlyukova@pgplaw.ru
www.pgplaw.ru