Stanislav Denisenko

Stanislav Denisenko

Director, Tax & Legal, Tax Dispute Resolution

KPMG in the CIS

Stanislav has about 25 years of practical experience in the legal sphere. He has been working with KPMG for 20 years. Before joining KPMG, he worked as the Head of the Legal Department at a Russian bank. Now Stanislav is the Head of Tax Disputes Resolution Group at the North-West Regional Center.

Stanislav has significant multidisciplinary experience in advising on various areas of law including tax and customs, currency, civil and labor law. A great number of projects was implemented under his supervision, including legal, currency, civil and customs risks' assessment in business, structuring of sustainable business models, business risk mitigation procedures, business restructuring, comprehensive transaction support, successful litigation support, etc. Stanislav has an impressive extensive experience in representing interests of KPMG clients in a wide range of tax disputes at pre-litigation and litigation stages, including in supreme courts.

His clients include major foreign and Russian companies engaged in various sectors, including transport and logistics, construction and real estate, manufacturing and trade, oil and gas, pulp and paper, pharmaceutical industry, mass media, telecommunications and entertainment, financial sector, infrastructure, etc.

His experience includes:

  • Success in the Supreme arbitration court on behalf of one of the leading developers on the commercial real estate market. Supported by the KPMG team headed by Stanislav, the client successfully appealed against additional tax charges of approximately RUB500 mln. Notably, the client engaged KPMG after the court of first instance and the court of appeal had denied the claims twice.
  • A tax dispute won for a major pharmaceutical company at all three court instances. The tax authorities had challenged the deductibility of costs of lectures delivered to medical workers, and the amount in question exceeded RUB100 mln.
  • A case won at all three court instances. It concerned the deductibility of management fees for the services rendered by the group service center for tax purposes in Russia. Despite the negative practice and low chances of winning, Stanislav managed to build up sustainable arguments, collect supporting documentation, and develop a strategy of presenting evidence to the court, which enabled the company to challenge tax charges totaling approximately RUB150 mln and also escape the same tax claims in the course of further tax audits.
  • Reversal of a resolution passed by the tax authority at the higher tax authority of St. Petersburg against a leading car manufacturer regarding transfer pricing issues. The tax effect for the company exceeded RUB100 mln. Remarkably, the higher tax authority had supervised the entire tax audit process from the very beginning, however, Stanislav and his colleagues managed to convince the higher tax authority that the company’s position was stronger.
  • Assistance to a foreign pharmaceutical distributor in reducing additional tax charges by a factor of 40 (from RUB100 mln to RUB2.5 mln) at the stage of considering tax audit materials.
  • Thanks to a well-thought defense strategy implemented while developing and considering objections to the tax audit report, a leading developer at the commercial real estate market managed to escape additional tax charges in the amount exceeding RUB70 mln at the stage of considering tax audit materials.


In the Media

An article for International Tax Review on the discussion around the Article 54.1 of the Tax Code of the Russian Federation.

Comments for Izvestia on the first case on illegal tax optimisation between the business and the Federal Tax Service heard by the Supreme Court.

Comments for RBC PRO on changes to tax legislation introduced in Q1 2021.

An article Forbes on the FTS clarifications on the criteria for assessing transactions involving one-day firms.

Comments for Vedomosti on the FTS clarifications on applying article 54.1 of the Tax Code of the Russian Federation.

Comments for Izvestia on the explanatory letter of the Federal Tax Service on the classification of payments between the members of one international holding company.

Comments for Kommersant and VTimes on the Federal Tax Service's initiative to restore the tax reconstruction practice.

Comments for Vedomosti on changing criteria for companies that may receive state support during the crisis caused by the Covid-19 pandemic.

Comments for RBC PRO on the formal grounds for denying state support to businesses.

An article for Delovoy Peterburg on a new Tax Code Article regulating the right of a taxpayer to reduce the tax base.

Areas of expertise
Arbitration Court Cases Disputes Documentation Litigation Mergers and Acquisitions Penalties Tax Tax Dispute Resolution and Controversy Transfer Pricing
Education and qualifications
  • St. Petersburg State University’s Law School

  • The Bonch-Bruevich Saint-Petersburg State University of Telecommunications, degree in engineering

  • Tax controversy leader 2014-2015 by International Tax Review

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