Althaus Group is a Russian advisory firm, part of WTS Global – the global network group of independent tax advisers. It employs more than 150 professionals in finance, tax, law, evaluation and engineering. The tax team, consisting of five partners, works closely with senior tax managers Ekaterina Kurochkina and Maxim Strazh, who assist on transfer pricing work. The TP practice assists on TP risks, TP policy, TP dispute, TP documentation and more.
The TP team advised logistic company DHL in carrying out benchmarking studies, transfer pricing documentation packages, defining the benchmarking research strategy and financial analysis.
International law firm Baker McKenzie offers a comprehensive transfer pricing service including economic and benchmarking analysis, TP documentation, MAPs, APAs and more. It has more than 660 tax lawyers in 77 offices located in 47 countries available to support in structuring cross-border transactions across multiple jurisdictions. Maria Kostenko and Arseny Seidov, tax partners, specialise in transfer pricing.
The firm assisted a dairy group company with preparing TP documentation, benchmarking analysis across Russia and Kazakhstan. The task involved aligning the TP model with the client’s local business operations in Russia and Kazakhstan.
BDO Unicon is an audit and consulting group with more than 1,500 employees in its network of offices in Moscow, St Petersburg and other cities in Russia. Sergey Chelyshkov and Vitaly Ivanenko, both partners, lead the tax department and transfer pricing practice. The TP practice provides assistance with APAs, TP documentation, TP study, benchmarking studies and more.
“The company offered a very good proposal for price and quality. All work was done in short time with high quality.”
Bryan Cave Leighton Paisner assists in tax and transfer pricing compliance and TP disputes. The firm’s global network spans across 32 offices in 11 countries, and has a platform of around 1,600 lawyers. Head of tax advisory Anna Zelenskaya and senior associate George Gutiev specialise in transfer pricing.
The team advised Puig Rus, cosmetic manufacturer, with localisation and adaptation of the global TP policy aligned with the Russian standards and producing a defence file for the tax authority. This involved researching and determining the relevant European benchmarks and economic analysis to use.
Russian law firm Cliff Legal Services is recommended for its tax legal services coverage and transfer pricing advisory. Head of tax Natalia Kordyukova and senior tax lawyer Marina Udalova specialise in transfer pricing.
The firm assisted a jewellery holding, with a significant presence in Russia, with the restructuring of its businesses. The complexity of the client’s structure – more than 20 companies in Russia and abroad – introduced risk on the tax aspects of the matter.
International law firm CMS provides full transfer pricing services, whether on compliance aspects, or on contentious aspects. The TP team has assisted numerous multinational companies and group holding companies with TP documentation, TP adjustments, TP audits and more. Managing partner Dominique Tissot heads the tax and TP practice.
The team assisted homeopathic producer Boiron with transfer pricing documentation, TP rules for loan agreements and more. The client has an operating presence in 59 countries and is one of the largest producers of homeopathic medicine.
Deloitte advises clients in tax and transfer pricing matters covering all compliance and contentious aspects. The firm has offices in Moscow, St Petersburg, Ekaterinburg, Ufa, Novosibirsk and Yuzhno-Sakhalinsk. The team specialises in advising on outsourcing and tax compliance, transfer pricing, tax dispute resolution and private client services. Tax partners Dmitry Kulakov and Vladimir Elizarov are key transfer pricing experts at the firm.
The team assisted one of the largest energy companies in Russia with transfer pricing compliance. The project entailed producing a master file and local file, with more than 75 controlled transactions a year, aligned with the BEPS directives.
Dentons has strengthened its tax department with the recruitment of 20 tax experts since November 2017, bolstering its transfer pricing department with the recruitment of three expert transfer pricing practitioners from KPMG and EY. The team has six counsels specialising in transfer pricing. The TP practice has lawyers, finance specialists, economists and accountants. Some of the clients it advises are Amazon, Nestlé, Volkswagen, Sberbank, Dyson and more.
The firm assisted an Austrian manufacturer group with thorough analysis of its CbC report. This involved reviewing the CbC report in respect to the OECD guidelines on tax risk indicators.
The EMEIA Tax Centre at EY is organised as a supranational entity covering the entire Europe, Middle East, India and Africa (EMEIA) region, with its Intercompany Effectiveness and operational transfer pricing practice serving clients’ needs across all jurisdictions. The tax practice is well experienced in complex TP services carried by experienced tax partners, economists, lawyers and consultants. The team also applies operating model effectiveness systems to identify efficient opportunities for efficient transfer pricing policy and more.
During the research period the tax practice assisted group companies with implementation of transfer pricing automated control System (TP ACS). This automates the collection of relevant data needed for preparation of TP notifications, data on intercompany transactions into analytical format and many more formatted data.
FBK Legal, a Russian audit and consulting firm, was established in 2012 as a spin-off from FBK’s tax and legal department. The transfer pricing services have experienced tax partners assisting in TP compliance and disputes. Lioubov Staroverova is the transfer pricing partner.
The team assisted Chernozeme, a reprocessing oil seeds company, with preparing TP documentation for controlled transactions valued at tens of millions of dollars. The team also assisted with tax risk analysis.
FinExpertiza’s tax department is experienced in providing tax legal services in industries such as oil and gas, transport, retail and wholesale, finance, construction, electricity and machine construction. The team has three senior tax practitioners specialising in TP advice. The key tax advice areas offered by the tax team are corporate, indirect tax, disputes, transactional tax, transfer pricing, M&A, real estate and construction. In addition, it offers a hotline for its clients to get online support on their tax issues.
The Russian law firm provides tax services and specialises in transfer pricing. The majority of the firm’s clients are international companies with offices in Russia. Tax partner Anton Kabakov is experienced in advising in new industries such as IT where transfer pricing is relatively new and transfer pricing adjustment mechanisms are also new in the Russian law and court practice.
PwC has a specialist transfer pricing team with 120 years’ combined experience. Andrey Kolchin and Natalia Kozlova are the transfer pricing partners leading the team. The accounting firm’s global transfer pricing team consists of 300 partners, and more than 3,100 fully dedicated transfer pricing professionals in more than 90 countries. It offers its clients full advice on transfer pricing matters such as documentation, APAs, Country-by-Country Reporting (CbCR), etc. The practice uses innovative technology tools to automatically collect information for TP analysis, reading agreements and other routine tasks. The firm has been innovative in developing strategies for clients to reduce the transfer pricing challenges from authorities and audits, and helps clients solve transfer pricing queries before the litigation stage.
The firm assisted the X5 Retail Group with general and transfer pricing advice regarding its transition to a new target group management structure. The TP aspect of the advice involved financial modelling, analysing the compensation under the developed agreements, supported by benchmarking studies, and more.
“PwC has a wide professional knowledge in specific Russian railway businesses, including transport, building, repair and research. This was crucial for the team to make competent and quick responses to our requests.”
Shapovalov Petrov Law Firm offers a full range of tax legal advice. This includes litigation, transfer pricing, due diligence, M&A tax and more. It has strengths in the media, mining, transportation and logistics industries.
The team assisted Panalpina, a Swiss logistics company, with a benchmarking study regarding royalty pricing and the use of trademarks under license agreements.
Taxology is an independent law firm focusing exclusively on tax legal matters. It provides full tax advice in areas such as controversy, M&A, transfer pricing and more. The team has acquired multinational clients such as Alpha Bank and Continental Tires among others.