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:

  • tax structuring (business reorganisation, business, financial and transaction modelling, risk identification and assessment);

  • international taxation (support of export/import transactions, services outside Russia, consulting support in foreign jurisdictions, audit and dispute support);

  • 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).


  • Pravo.Ru-300 2022 — Tax Controversy Practice areas


Industry specialization
Industrial production and engineering
Retail / FMCG
Pharmaceuticals, healthcare
Construction / Real estate / Development
Food industry

Practice areas
  • Tax structuring
  • Transaction taxation
  • Tax consulting
  • Tax litigation
  • International tax planning


Plekhanov Russian University of Economics, finance and credit
Moscow Academy of Economics and Law, jurisprudence
Russian Ministry of Finance, auditor’s qualification certificate

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
  • 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



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