Denis Khramkin

Senior Associate

Denis focuses on tax law, specifically corporate taxation, tax structuring matters and tax disputes. 

His expertise includes advising Russian and transnational corporates on their business in Russia and abroad, specifically investment taxation, business structures and current operations, including in cross-border deals and transactions. 

Denis has provided legal help to clients engaged in such sectors as e-commerce, oil and gas, manufacturing, pharma, FMCG, trade, transport, TMT, IT, etc.

He has a successful track record of advising clients during tax audits and tax disputes both in and out of court, including direct representation before tax and court authorities.

Denis has also been involved in voluntary tax audits identifying tax risks and overpayments and in tax due diligence checks on target businesses. 

Track record

Denis’s recent projects:

  • Advising HeadHunter Group on various tax issues related to tax residence status obtained by the Cyprus holding company, including advice on employee option plan taxation.
  • Advised a leading global e-commerce travel platform on possible tax risks in Russia resulting from a foreign company billing Russian tourists and from billing being transferred to a Russian company of the group from a company in a foreign jurisdiction.
  • Provided structuring advice to an international online marketplace on tax and regulatory structuring issues related to operation of its online platform on the Russian market with respect to engaging with local merchants.
  • Advising a leading manufacturer of railway rolling stock on tax and currency issues associated with restructuring (refinancing) a loan from a Russian bank, as well as bonded debt.
  • Advising a major Russian manufacturer and importer of climate control equipment on tax restructuring of asset holdings including ultimate beneficiaries setting up a foreign private fund and personal holding companies in a European jurisdiction, as well as re-domiciliation of a foreign trading company of the group from one European jurisdiction to another.
  • Preparing a legal opinion on tax matters related to sale by a Singapore company to an Irish company of an air engine used on an aircraft owned by a Russian airline , and also on subsequent securitisation of claims arising out of a leasing contract for the aircraft engine.
  • Advised a Russian subdivision of a transnational group providing management system certification services on tax implications and assessment of tax risks associated with using an intra-group cost allocation model based on indirect pricing and with having appropriate documents issued for such business transactions.
  • Advised a Russian subsidiary of an international coffee product maker on assessing tax risks triggered by the tax authorities possibly re-classing a loan from a foreign parent as investment (capital) in order to tax it at the Russian subsidiary level.
  • Negotiated with a Russian regional government the granting of priority investment project status and corporate property tax exemption of more than RUB 250 m to an oil refinery upgrade project.
  • Successfully represented a Russian subsidiary of an international pharmaceutical company in a tax dispute over additional profit tax totalling approximately RUB 17 m due to the tax authorities refusing to recognise the contingency for paying annual bonuses to employees as costs.  
  • Acted for a major manufacturer in the North-West of Russia in having a tax dispute over a refusal to refund more than RUB 35 m in VAT from the budget settled successfully out of court.
  • Advised a subsidiary of a major global gas producer during its field tax audit and participated, at the pre-trial stage, in settling a tax dispute over refusal of preferential corporate property tax rates for power lines.