Denis Kozhevnikov

Associate

Throughout his career, Denis has obtained significant tax experience while he was working for top law firms in Russia and one of the Inter-Regional Inspectorates for the Largest Taxpayers.

In particular, Denis was involved in judicial and pre-judicial representation of the major Russian companies in different fields, including electric power industry, oil and gas, mail delivery and others. Along with extensive litigation experience, Denis is largely involved in tax consulting projects related to transactional management and tax risk analysis.

Prior to joining BCLP, Denis was a tax associate at Vegas Lex, the Russian-based law firm.

Some of his recent dispute resolution projects include: (*)

  • Representation of a large Russian power generating company in the series of court cases related to exclusion of industrial buildings from a list of objects taxable on the basis of cadastral value, deduction of losses from assignment of rights, deductibility of «golden parachutes», retroactive effects of cadastral value changing, etc.;
  • Representation of one of the largest oil producing companies in the dispute related to judicial request of VAT invoice (more than 3,3 billion rubles value);
  • Protection of interests of a large agricultural group in the dispute concerning application of «thin capitalization rule»;
  • Dispute between a large electronetwork company and a tax inspectorate regarding taxation of non-contractual electricity consumption;
  • Representation of a petroleum refinery in the dispute concerning qualification of a particular type of fuel as an excisable one.

Some of his recent consulting projects include: (*)

  • Tax support of a large investment partnership at various stages, including the process of setting up a partnership and its functioning. Work on projects related to this investment partnership was complicated by specifics of investment partnerships’ taxation regime and included multiple transactions such as barter deals, loans, assignment of rights and transfer of obligations;
  • Consulting related to taxation of non-monetary compensation for dismantling of utility objects and social facilities;
  • Risk analysis related to arrangement of a bank credit line and back-to-back loans between associated companies, including analysis of tax consequences of the payment of specific bank fees;
  • Analysis of existing charter agreements and development of the structure of transactions for one of the largest Russian companies in order to minimize tax risks, including recognition of the application of a zero percent rate of VAT as illegal;
  • Risk analysis related to existing transactions and structure of a big pharmaceutical group.

(*) Including experience prior to joining BCLP