Anton Stepanov

Anton has more than 15 years’ experience in legal and tax advisory and pre-litigation or litigation stages of tax dispute resolution, as well as in supporting clients during field and desk tax audits and successfully challenging tax authorities’ claims.

He represented one of the largest Russian airline companies, at pre-litigation 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 pre-litigation 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:

• Cases No. А40-48773/2020, А40-114650/2020, А40-253076/2020, А40-247705/2020, А51-18467/2020, А51-16217/2020, А51-18477/2020, А60-46173/2020 – regarding utilization (scrap) fee refund for cargo vehicles (chassis)
• Cases No. А40-197273/2020, А51-18478/2020, А41-41829/2019, А41-13101/2019, А41-3245/2019, А41-2226/2019, А41-102386/2018 – regarding utilization fee (scrap) payments for vehicles that were re-imported to EAEU-member countries
• 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.