Ekaterina Subbotina

Senior Lawyer

Ekaterina specialises in tax advisory and complex advisory involving tax, civil and other branches of law. She has over 20 years of experience and expertise in tax law, tax dispute resolution, civil law, advisory on matters related to taxation (civil, land, investment, town-planning, intellectual property law) and support of complicated judicial disputes (including support of case consideration in the Presidium of the Supreme Court of the Russian Federation).

Ekaterina advises clients on tax risks associated with Russian and cross-border transactions (matters concerning taxation of e-services, creation, accounting treatment and disposal of intellectual property), and tax matters related to investments in construction. She has experience of participation in big consulting projects related to structuring of businesses, including businesses with international elements.

Ekaterina has also been involved in contractual and litigation work aimed to protect interests of big owners of real estate, including land assets (public and private subjects) and assisted clients during various audits (conducted by tax authorities, competition regulators and law enforcement agencies).

She passed an arbitration judge qualification exam (with top marks).

Major projects:

  • Assisting a Russian subdivision of a transnational company (a leading manufacturer of home appliances, consumer electronics and IT products) in dealing with all business contracts (tax due diligence, tax review of contracts);
  • Preparing detailed analytical studies of tax and other risks, advising on their mitigation and developing the taxpayers strategy for potential disputes over:
  • new requirements for mandatory pre-installation of Russian software (for manufacturers and sellers of technologically sophisticated products),
  • joint marketing and advertising campaigns (co-branding programmes),
  • contracts for retailing of goods through a big transnational marketplace,
  • cross-border sales and purchases of software rights;
  • acquisition of transportation and logistics services for international carriage;
  • Preparing an analytical study of the organisational structure of a group of companies (an international group), tax aspects of intercompany services and advising on risk mitigation;
  • Analysing and advising on the applicability of the 10% VAT rate for sales of certain food products (analysing different options and preparing arguments for a potential tax dispute (for a fast food restaurant chain));
  • Assessing tax risks associated with the construction of a production facility (extraction and processing of minerals), finding the best legal way to formalise the investors ownership;
  • Analysing and advising on tax aspects and business structuring risks for a big federal retailer;
  • Managing tax payment collection to the budget of a big Russian city;
  • Preparing objections to findings of an on-site tax audit of a coal company to defend the company from tax claims at the pre-trial stage (the total amount claimed was over RUB 4 bn this is one of the biggest tax cases of the last five years in the Siberian Federal District);
  • Preparing objections to findings of an on-site tax audit of a consolidated group of taxpayers and participating in their consideration;
  • Assessing tax liabilities and risks associated with the provision of free meals to employees of a fast food restaurant chain.

Practice areas

Tax consulting, assistance during pre-audit analysis of taxpayers, assistance with contracts (tax due diligence and tax review of contracts), comprehensive advisory on tax, civil and other branches of law, tax and other disputes


1997 Chelyabinsk State University, Degree in Law



Sector experience
  • IT / TMT / Technology
  • Trade
  • Advertising/marketing
  • Construction / Real estate / Development
  • Public catering
  • Oil&gas
  • Coal industry
  • International transportation and forwarding services