Dmitry Knizhentsev
Dmitry Knizhentsev is a Partner at FBK Legal.
He has worked in taxation since 1997.
Before joining the FBK Legal team, he worked for tax police, tax authorities and EY.
He specialises in:
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tax structuring (business reorganisation, business, financial and transaction modelling, risk identification and assessment);
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international taxation (support of export/import transactions, services outside Russia, consulting support in foreign jurisdictions, audit and dispute support);
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customs support (customs formalities, appealing against findings of customs authorities).
He participates in hearings of tax, customs and foreign currency cases in arbitration and general jurisdiction courts; conducts tax audits and tax due diligence.
Dmitry has teaching experience (lectures on tax law, seminars/webinars on various taxation matters).
Ratings
- Pravo.Ru-300 2022 — Tax Controversy Practice areas
Specialization
- Tax structuring
- Transaction taxation
- Tax consulting
- Tax litigation
- International tax planning
Education
Major projects:
- Justifying the application of the look-through approach for income payment to holding structures in the Netherlands, Switzerland and Luxembourg for a big packaging manufacturer (a positive effect of RUB 1bn)
- Documenting expenses of a Russian company related to intercompany financing from foreign members of the group (the Netherlands, Belgium) for a big international pharmaceutical group (a positive effect of RUB 900m)
- Supporting control procedures related to a refund of VAT on information processing services to a foreign company of the group (Singapore). The VAT was fully refunded (a positive effect of RUB 870m)
- Confirming the justification and documentation of expenses incurred to engage sub-contractors — affiliated foreign companies — for a big consulting company (a positive effect of RUB 600m)
- Developing, analysing, collecting and systematising documents and information supporting expenses incurred by a Russian company with respect to intercompany services involving international message transmission via telecommunication channels (a positive effect of RUB 282m)
- Consolidating and optimising assets of a big Russian manufacturer in Russia and abroad, including modelling and assessment of tax implications and risks associated with transactions
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Justifying the application of the 5% rate for customs duties under a WTO Agreement for a big packaging manufacturer. The company’s position was confirmed by the court of cassation that annulled decisions of lower courts
- Support to obtain and use an investment tax incentive related to the 2018 FIFA World Cup for a big international airport
- Support of negotiations between the tax authority and a big international food company to develop a uniform approach for the measurement of intercompany expenses
- Successful appeal against claims of the tax authority totalling RUB 200m to a big investment and development company with respect to intercompany financial flows
- Negotiating with the tax authority an approach to property qualification as movable/immovable as part of the representation of a big metals company in Russia
Languages
English
