Anna Zelenskaya

Counsel, Head of Tax Advisory (Russia)

Anna heads the Tax Advisory group with the Moscow office and has a vast experience in consulting of multinational businesses on their investments in Russia, including multijurisdictional tax structuring and advice. Anna specializes in tax restructurings both for corporate and private clients, support of M&A transactions at all stages, starting from tax due diligence to deal structuring and SPA revisions and negotiations, as well as tax advice for e-commerce and IT businesses.

Anna supports clients acting in such industries as pharmaceuticals, automotive, FMCG, electric equipment manufacturing, oil & gas, retail and other. Anna acts as a member of two AEB Taxation Committee Working Groups: on VAT on Electronic Services and Tax on Intragroup Services.

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 2018-2021 Edition. Anna is included in Group 1 by a leading Russian legal ranking Pravo.ru-300 2019 in tax consulting and in Rising Stars list – by Legal 500 2020.

Anna was mentioned in World Transfer Pricing 2014 / International Tax Review as recommended by clients for “for professionalism, scrupulousness, high availability”. 

Track record

Some of the projects in which Anna has participated include:

  • Advising HeadHunter Group PLC (the leading online recruitment platform in Russia and the CIS focused on providing comprehensive talent acquisition services) on various tax issues related to the group restructuring, while the company was engaged in the IPO process, including relocation to Russia in terms of effective management and tax residence status obtained by foreign companies, advice on various intragroup financing and profit repatriation issues, employee option plan taxation.

  • Advised Kuzbassenergo (a leading operator on the Russian electricity and thermal energy market) on various tax aspects of the acquisition of Reftinskaya GRES coal-fired power plant from Enel Russia.

  • Provided pre-acquisition tax due diligence and relevant advice to Da Vinci Capital in connection with its investment in DataArt.

  • “Localisation” and adaptation of the Global TP Policy of PUIG to the Russian standards and drafting a defence file for Russian tax authorities.

  • 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 Weatherford, including pre-acquisition tax due diligence of oil field services enterprises of a major Russian oil producer.

  • Advised BASF 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.