Gerenzal challenges tax claims and supports companies during tax audits and pre-audit analysis: analysing document, information or explanation requests from tax authorities and preparing motivated replies to them, giving oral and written advice on questions posed by tax authorities before making a decision on an on-site tax audit or during audits or on-site tax control procedures, analysing whether tax authorities’ actions are legal, whether the company assesses tax correctly, training taxpayer employees before interrogations, participating in interrogations as a representative of interrogated persons.
Gerenzal also specialises in tax risk assessment.
Thanks to over 15 years of experience in tax consulting, she has thoroughly studied the nuances, features and risks arising from the controversial tax legislation in Russia and practices of tax authorities.
She provides high-quality services due to her vast experience in preparing objections to tax audit findings, participating in the review of tax audit documents and providing support during tax audits.
• preparing a complaint to the Russian Supreme Arbitration Court related to a dispute over taxpayers’ right to recognise an exchange difference on dividends in deductible expenses for income tax purposes;
• representing a client in a judicial dispute with the Interregional Inspectorate of the Federal Tax Service that deals with major taxpayers over the right of Gazprom’s subsidiary to deduct VAT on property acquired by the subsidiary at the expense of the investor (PJSC Gazprom) more than three years after the event;
• representing a client in a judicial dispute with the Interregional Inspectorate of the Federal Tax Service that deals with major taxpayers over the right of the customer under a general contractor agreement to recognise construction and assembly risk insurance expenses as deductible expenses for income tax purposes if the customer obliges the general contractor to insure construction and assembly risks under the agreement;
• preparing objections to tax audit findings related to Gazprom’s subsidiaries and participating in the review of tax audit documents;
• preparing objections to tax audit findings related to the Sovcomflot Group;
• preparing objections to tax audit findings related to a big fish trader, participating in the review of tax audit documents, supporting the company during tax control procedures.
Support during tax disputes, challenging tax claims, support during tax control procedures as part of tax audits and before them
1996 Volgograd State University, Faculty of Law