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Anton Stepanov
Director, KPMG Law, Dispute Resolution
KPMG in Russia and the CIS
Anton has about 15 years’ experience in legal and tax advisory and out-of-court or in-court tax dispute resolution, as well as in supporting field and desk tax audits and successfully challenging tax authorities’ claims, specifically out of court.
He represented one of the largest Russian airline companies, at an out-of-court stage, in the course of challenging findings of a field tax audit which resulted in charging by the tax authority of additional withholding tax in the amount in excess of RUB 5 bln on income paid to foreign lessors. Additional tax charges related to this episode were successfully challenged at an out-of-court stage.
During the last few years, Anton also succeeded in challenging cadastral values of real estate properties in favor of high-profile global investment funds and banks.
Anton’s experience also includes successful defense of client interests in disputes re UF collection and realization of projects on utilization fee refund. Over the last few years in the field, Anton managed projects which resulted in tax refunds to clients from the budget (reimbursements/offsets) in a total amount exceeding RUB 15 bln.
Anton’s recent project experience includes representation of clients in the following tax disputes:
- Case No. А41-64958/2019 in the dispute on the relevance of applying an investment tax benefit provided for by regional laws
- Case No. А59-8433/2018 in the dispute on the possibility of applying a beneficial tax rate (5%) under a DTT with the Republic of Cyprus to dividend payments (the only case won by taxpayers in the area of the ‘beneficial owner of income’ concept with respect to dividends)
- Case No. А40-84820/2018 in the dispute on the procedure for determining a 3-year period for claiming VAT deductions
- Case No. А27-13534/2016, No. А60-7484/2017 and А60-22612/2018 in disputes on the relevance of applying a tax benefit to facilities with a high energy efficiency rating
In the Media
Comments for Kommersant on a proposal to limit to 10% growth in tax payments calculated on the basis of cadastral value for the owners of commercial real estate for 2020 and 2021.
Comments for Vedomosti on an amendment to Article 29 of the Russian Tax Code, which determines the status of the authorised representative of a taxpayer.
Comments for RBC on including VAT in cadastral property values.
Comments for Vedomosti on tax disputes on intra-group financial transactions.
Comments for RBC on identifying the real beneficiaries of tax optimisation schemes.
Comments for RBC on a case where additional profit taxation was challenged in the court of Kemerovo Region.
An article for Pravo.ru on claims from the tax authorities that management companies have to frequently deal with, and effective ways to contest them.
Education and qualifications
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Russian Academy of Justice, Degree in Jurisprudence