Sergey Kalinin
Counsel, Head of Tax Practice

40/5 Bol. Ordynka St.,
Moscow, 119017, Russia

Tel.: +7 (495) 935 8010
Fax: +7 (495) 935 8011

sergey_kalinin@epam.ru

«Outside-the-box thinking when it comes to problem solving and his personal approach to the client»

Chambers Europe

Sergey has considerable experience in advising corporate clients on a wide range of Russian and international tax issues, in particular, in the field of tax structuring of transactions and investments, taxation of financial instruments and derivatives. Sergey successfully represents clients in tax disputes. He also has a wealth of experience in advising private clients on deoffshorization and amnesty of capital.

Before joining the Firm, Sergey Kalinin was a Tax Partner at Liniya Prava, he also he also worked at Russian law firm, international law firm and at one of Big Four accounting firms.

His experience highlights include:

  • Advising Bank Saint Petersburg, the largest privately-owned universal bank in North-West Russia, in the transaction involved the sale of the bank's portfolio of mortgage loans to a special purpose vehicle (a mortgage agent) and the subsequent issue of bonds backed by mortgage collateral comprising prime mortgages. Matter value: RUB 3.7bn.
  • Advising one of the largest airlines in Russia on tax issues related to their new bonus program.
  • Advising VTB Capital on tax consequences and risks related to a REPO transaction; advising on tax consequences and risks associated with the issue of ruble bonds with a variable coupon tied to inflation index, and transactions of interest-bearing promissory notes.
  • Drafting the securities prospectus description of taxation of income paid to resident and non-resident holders of the bonds for VTB Capital Finance.
  • Advising Vnesheconombank on the investment tax consequences with regards to the investment partnership agreement and the contract of trust management.
  • Advising Rusnano on various issues related to the floating and business of the investment partnership – a legislative instrument for Russian pooled investment.
  • Advising a Russian venture company on tax and other issues related to the analysis of the incentive mechanisms of the direct and venture investment, as well as drafting relevant amendments to the current tax legislation.

Sergey’s experience in representing clients in tax disputes includes:

  • Representing Shell Oil in an arbitration with the tax authorities on the legal recognition of consulting services expenses rendered within the group.
  • Representing a client in a dispute with the tax authorities on reasonable costs for the payment of the external loan interest used for the intra-group financing.
  • Representing one of the largest international oil and gas companies in an arbitration with the tax authorities on costs arrived at by the PSA operator in the calculation of income tax, as well as other contentious PSA application issues.
  • Successfully representing ANO "Center of arbitration proceedings" in a dispute with the tax authorities on VAT exemption of the arbitration fee.

Sergey graduated from the law faculty of The State University of Land Use Planning. He holds a Ph.D. (Graduate School of the financial faculty at Kutafin Moscow State Law University) and an LL.M. in international taxation (Vienna University of Economics and Business).

He is a permanent member of the Russian branch of the International Fiscal Association (ROS-IFA) and the Moscow Bar Association.

Sergey speaks fluent English.

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