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Tax controversy and dispute resolution

Globalization, changing business processes and the need to ensure an effective revenue stream for the government are the factors that force the tax authorities not only to review their current approaches to tax administration, but also to re-examine their relations with the business community.

68% of respondents report that they feel tax authorities globally have increased their focus on cross-border transactions*

In recent years, tax authorities have reconsider the way they prepare and implement tax control measures, established effective information exchange between government stakeholders both within and outside Russia and come up with systematic approaches to assessing the tax implications of cross-border and industry-specific transactions in line with international practices and OECD recommendations. The competencies of tax administrators as well as the quality of tax audits have improved considerably.

These developments have led to more tax disputes resulting in an outcome which is difficult to predict. There are high chances that this trend will remain in the future amid a change in law enforcement practices and tax legislation.

Therefore, in the event of tax disputes it is especially important for the taxpayer to properly build relationships with tax authorities and to protect themselves from possible reputational and financial risks associated with claims of tax authorities.

Having no experience, it will be rather difficult for the taxpayer to achieve the intended effect: special nature of tax disputes is such that the tax authority has some advantage over the taxpayer due to the possibility to use a wide range of administrative powers of tax control, while most taxpayers face tax disputes only occasionally.

It is therefore convenient to entrust the settlement of tax disputes to specialists who are frequently involved in communication with the tax authorities and know their approaches to transaction review, collection of evidence and carrying out tax control measures, and can effectively contest their assessments.

We offer a broad range of services — from preventing tax disputes to supporting clients in dispute resolution at all stages, from administrative appeals to judicial proceedings.

EY’s tax controversy and dispute resolution services

EY’s tax controversy and dispute resolution services.


The EY difference

The EY difference

Why EY

We have tremendous experience in resolving tax disputes over both cross-border and domestic transactions. We will successfully protect your rights in any tax disputes, including those relating to the following:

  • Applying reduced tax rates or tax reliefs under double tax treaties
  • Confirming the status of the beneficial owner
  • Applying thin capitalization rules and reclassifying interest to dividends
  • Operations of a foreign representative office in Russia
  • Economic justification and documentary evidence of various costs for income tax purposes
  • Determining the tax period to which income and expenses relate
  • Limitation certain types of expenses
  • Due care in the selection of counterparties
  • Refund or deduction of input VAT
  • Pricing of controlled transactions for tax purposes
  • Performing tax agent’s functions
  • Requalification of transactions

Specialist practice groups and industry expertise

Advising our clients, we consider their industry specialization and involve specialists of various service lines, which ensures the high quality of our services.

EY - Specialist practice groups and industry expertise

* EY’s 2014 Tax Risk and Controversy Survey

Contact us

Alexandra Lobova 
+7 (495) 705 9730

Alexei Nesterenko 
+7 (495) 662 9319


Connect with us

Our experience

Experienced team of professionals with unique knowledge, combined with focused specialization and industry-specific knowledge. With EY support, more than 100 tax disputes were settled in Russia over the past two years, 95% of disputes – in favor of our clients. Learn more.

Our team

Tax steps into the light

Learn more from EY’s 2017 Tax Risk and Controversy Series.

Our awards

Alexandra Lobova, partner, and Alexei Nesterenko, partner, were named among the best Tax Controversy Experts in Russia in 2017 by International Tax Review.

Vladimir Kotenko, partner, was named among the best Tax Controversy Experts in Ukraine in 2017 by International Tax Review.

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