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Victor Arkhipov



Background information

Mr. Arkhipov has got a wide experience in advising on tax law matters and presenting of clients’ interests in tax disputes.Prior to joining the firm, Victor Arkhipov worked in tax practices of Pepeliaev Group in 2006-2017 and in FBK in 2002-2004.


  • International comparative law course at Leiden University (the Netherlands)
  • The Russian School of Private Law (Master’s degree in Private Law, 2002)
  • The Faculty of Law of Moscow State University (summa cum laude, Diploma in Law, 2000)

Victor advises on the following issues:

  • advising on tax consequences of current business activity in relation to the Russian income tax, VAT, the property tax, the personal income tax, insurance premiums;
  • advising on tax consequences of planned transactions on acquisition/sale of assets, shares in companies and enterprises, investment transactions;
  • advising on tax consequences of the planned forms and ways of restructuring, consolidation of assets, companies and enterprises;
  • issues of the cross-border taxation for the Russian and foreign companies / individuals
  • income tax from sources in the Russian Federation and VAT for foreign companies which are carrying out the activity in the Russian Federation or selling goods, works and services to the Russian companies and individuals;
  • creation of permanent establishment and other tax obligations for the foreign companies carrying out business activity in the Russian Federation;
  • issues connected with application of Russian legislation on the controlled foreign companies, thin capitalization, transfer pricing, etc.
  • representation and protection of interests of Russian and foreign companies and also individuals at all stages of interaction with tax authorities (both prior to tax inspection and during its conducting and also after its finishing within pre-judicial and judicial disputing of acts, decisions and illegal actions / inaction of tax authorities).

The recent selected experience of Mr. Arkhipov includes:

  • advising and representation of interests of the American real estate fund on acquisition of the commercial real estate objects in the territory of the Russian Federation and also at subsequent negotiations and sale of properties and divestiture;
  • representation of interests of a large foreign company in the sphere of production and oil refining on a dispute with the Russian tax authorities;
  • advising on tax implication and deal structuring on acquisition and sale of assets in the territory of the Russian Federation by European, American and Asian companies;
  • advising on restructuring of strategic state companies and on relations with foreign investors and shareholders taking into account US and EU sanctions
  • drawing up enquiries to the Federal Tax Service of the Russian Federation, the Ministry of Finance of the Russian Federation and also participation in preparing legislative acts and proposed changes in the tax legislation of the Russian Federation
  • assistance to foreign investors and service providers in registration with the Russian tax authorities (on a so-called “Google tax “) and representation of their interests in interaction with the Russian tax authorities;
  • search and finding out clients’ tax overpayments and also representing their interests in interaction with tax authorities on refund or set-off of excessively paid taxes, including in court proceedings.