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Marina Arakelova

B1 Senior Manager Moscow

Tax Policy and Controversy, Tax, Law and Business Support

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Professional experience

  • Marina joined the firm’s Moscow office in 2003 and has over 25 years of experience in tax policy and controversy

  • Marina has considerable hands-on experience in representing the interests of Russian and foreign companies with the tax authorities and other government bodies, and assisting them in the settlement and resolution of tax disputes both at the out-of-court stage and in court

  • She focuses on tax debt restructuring (arranging for installment tax payments, tax deferrals, amicable agreements), evaluating the financial standing of a company to identify risks that may arise due to inability to pay additionally assessed tax liabilities, dealing with injunctions requested by the tax authority (including their replacement or cancellation) and cases where controlling persons or executive officers of an organization are brought to subsidiary liability in the context of tax relations

  • Marina contributes to consulting projects by providing services to Russian and international companies related to the legitimacy of using lower tax rates or tax benefits, including under international tax treaties, the requalification of transactions under the concept of abuse of law, the recognition of a permanent establishment of a foreign company in the Russian Federation, and the confirmation of the status of beneficial owner of income

  • Marina is the author of practical and academic articles on taxation, tax control and tax dispute resolution

  • She organizes and participates in professional tax workshops and conferences

  • She also engages in teaching and contributes to conducting courses in Financial and Tax Law at HSE University and Kutafin Moscow State Law University

Competencies

  • Assisting companies in tax debt restructuring and evaluating their financial standing to prevent bankruptcy risks as well as in replacing or canceling the injunctions requested by the tax authority 

  • Protecting the rights and interests of controlling persons and executive officers of companies in the event they are brought to subsidiary liability in the context of tax relations

  • Providing professional support in the settlement of tax disputes between companies and the tax authorities out of court and in court

  • Representing the interests of Russian and foreign companies with the tax authorities and other government bodies as part of control activities

Education

  • Honors graduate of Kutafin Moscow State Law University qualified as a lawyer

  • Institute of Law and Comparative Jurisprudence under the Government of the Russian Federation, Ph.D. in Law