Olga Krivitskaya is a Senior lawyer at Tax litigation practice, FBK Legal.
Has over 10 years of experience in tax law and tax disputes resolution.
Olga has extensive experience in the area of tax dispute resolution, including high-profile disputes, in courts of arbitration and tax authorities.
Olga also advises clients on and takes part in engagements which involve application of transfer pricing legislation and provisions of double taxation treaties.
Has experience in delivering presentations (seminars) in tax.
Olga’s success track record includes:
- challenging additional tax charges imposed on the Gazprom entities, including in the transfer pricing area, specifically, applicability of the cost plus method and relevant application principles as these pertain to unique facilities or facilities built in unique business conditions, including facilities built under interstate agreements;
- refund of VAT to a Gazprom group subsidiary in a dispute over a 3-year omission of a VAT refund term;
- identification of tax overpayments, including within the engagement for Russia’s largest global energy company, to reduce the tax liabilities of companies operating in aggressive environment;
- successful pretrial settlement of a dispute with tax authorities on behalf of a Russian subsidiary of one of the world’s leading health-promoting beverage manufacturers, including provision of evidence of invalidity of tax claims associated with the tax treatment of royalty for the use of the Holding’s trademark;
- successful challenging of the tax claims against largest oil&gas companies, electric companies, aviation entities and other tax-paying entities.
Tax dispute resolution, support in tax inspections, pretrial appealing tax authorities decisions, transfer pricing
2003 Lomonosov Moscow State University, Law