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Alexander Erasov

Head of Tax Dispute Resolution Group | Tax Crime Defence

Alexander focuses on tax litigation, tax dispute resolution, tax crime defence and tax advisory services.

Before joining Goltsblat BLP, Alexander worked with the tax litigation and tax dispute resolution practice of Ernst & Young.

At the start of his professional career, Alexander worked with the Russian tax authority responsible for the administration of all foreign companies with branches and representative offices in Moscow.  This allowed Alexander to develop a deep understanding of internal processes and administrative procedures and how to use them effectively in the client’s favour.

Alexander has accumulated considerable experience of supporting clients during both field and desk tax audits (including audits related to the refund of VAT and other taxes as well as audits performed in the process of a company’s liquidation) and experience of successfully defending clients in disputes with the tax authorities during both pre-action and court stages. This includes the preparation of all necessary documents and the representation of clients’ interests in court and to government authorities.

Alexander has also extensively advised international and Russian companies regarding the tax consequences of various transactions, Russian and international tax planning and tax optimisation, structuring of operations and establishment of businesses, transfer pricing and permanent establishment issues.  Additionally, Alexander participated in a series of tax review projects that included tax due diligence reviews on the acquisition of Russian targets by foreign and domestic investors.

Track record:

  • A major Russian railway carrier.  (1) Successfully challenging additional tax charges of withholding tax based on the Tax authority applying the dependent agent concept. In this case, the loan agreement with the Cyprus company was signed by a Russian physical body on the ground of respective power of attorney (the amount in dispute was about 2.8 million USD). This case was the first court case in Russia concerning the application of the dependent agent concept. (2) Successfully challenging the Tax authority’s refusal to reimburse VAT based on the treatment of transactions related to the acquisition of cistern wagons as sham transactions (the amount in dispute was about 25 million USD).
  • A major international pharmaceutical company. (1) Successfully resolving a tax dispute with respect to the Tax authority’s refusal to refund a tax overpayment due on the expiration of a 3-year period (the amount in dispute was about 3 million USD).  (2) Successfully challenging several Tax authorities’ decisions in respect of input VAT relating to the acquisition of marketing and information services (the amount in dispute was about 3.5 million USD).  (3) Successfully challenging additional charges for failing to meet the date to submit a tax return. Contesting the decisions in a judicial procedure led to the fines being reduced to 100 RUR (the amount in dispute was about 0.2 million USD).
  • A major German automaker. Successfully challenging additional tax charges imposed by Tax authorities because of leasing security deposits being requalified to the Company’s income, at the moment that they were received by the Company. The Company, which was acting as a lessor in the leasing agreements, had treated the security deposits as advance payments. (the amount in dispute was about 5 million USD).
  • A major German bathroom and lavatory equipment producer. Successfully challenging additional tax charges that related to the treatment of bonuses and advertising expenses for VAT and profits tax purposes (the amount in dispute was about 0.7 million USD).
  • A Cyprus company that owned immovable property in Russia. Participated in successfully challenging the Tax authority’s refusal to reimburse VAT based on the ground that the Cyprus company was registered as the immovable property owner with the Russian tax authorities , not as a branch or as representative office (the amount in dispute was about 0.8 million USD).

Alexander is a member of the International Fiscal Association (IFA), gives lectures on tax law at the Kutafin Moscow State Law University (MSAL) and serves on the Tax Committees of the Association of European Businesses and the American Chamber of Commerce in Russia.

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