Anna Zelenskaya

Counsel, Head of Tax Advisory (Russia)

Anna specialises in tax consulting of multinational businesses on their investments in Russia, including multijurisdictional tax structuring and advice. Prior to joining BLP Anna worked with Baker&McKenzie Russian tax practice. She has been advising on taxation matters and providing assistance to Russian and foreign companies on their activities in Russia, mainly on taxation of domestic and cross-border investments, business structures and activities, corporate restructurings and permanent establishment issues. Anna supported clients acting in such industries as pharmaceuticals, automotive, FMCG, electric equipment manufacturing, oil & gas, retail and other.

Anna has participated in and led a number of internal tax health-checks, pre-IPO and pre-M&A tax due diligence reviews. In addition to that Anna has experience in successfully handling tax controversies and tax litigation at all stages from pre-trial support to cassation appeals in disputes with the tax authorities. 

Anna is also focusing on handling transfer pricing issues and is leading projects on full-scope preparation of TP documentation. Anna was mentioned in World Transfer Pricing 2014 / International Tax Review as recommended by clients for “for professionalism, scrupulousness, high availability”. 

Anna was selected by peers as one of the best lawyers in Russia in the field of Tax Law, according to Best Lawyers in Russia 2018-2020 Edition.

Track record

  • Provided tax structuring advice and tax support on a variety of M&A transactions on sale of Russian businesses.
  • Advised a major Japanese investment and trading corporation on various options of investment into Russian real estate.
  • Developed restructuring options and provided tax advice as a part of complex on a restructuring project covering all business areas of a major MNE retailer in Russia to account for new functional and asset profiles.
  • Structured intragroup licence agreement for several Russian businesses of global manufacturing MNEs in terms of a complex project of transferring to an alternative licensing model.
  • Developed and implemented a profit allocation methodology for a Russian permanent establishment of a UK-based engineering consulting firm operating in 35 countries worldwide.
  • Performed a transfer pricing study and prepared TP documentation under the Russian rules for the Russian entities of Sanofi international pharmaceutical group.
  • Participated in a series of full-scope tax due diligence for a US oil-field servicing company, including pre-acquisition tax due diligence of oil field services enterprises of a major Russian oil producer.
  • Advised a German chemical manufacturer on tax consequences of restructuring options aimed at consolidation of its Russian business units as a part of complex restructuring advice.
  • Led a series of health-check reviews and internal audits of tax compliance, risks and tax saving opportunities identification for several major MNE perfume and cosmetic product distributors.
  • Advised an Italian pharmaceutical company on tax aspects of restructuring its Russian distribution activities and transfer to a new business model in Russia.