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Pavel Kondukov

Partner, attorney — Tax Advise and Disputes, Lawmaking and GR
pavel.kondukov@bgplaw.com
Pavel specialises in tax advising, tax litigation, lawmaking and GR. He provides advice on controversial aspects of Russian and international taxation, transaction structuring, preferential tax treatments and benefits, and conducts tax audits. He supports deals (transactions) requiring government authority approval (authorisation). Pavel has vast experience in developing and supporting lawmaking initiatives. He also advises on enforcement of FX and counter-sanctions laws, including by providing legal support for obtaining transaction authorisation from the Russian Government Commission on Monitoring Foreign Investment.

Adwards

Legal 500
Past Experience
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Before joining BGP Litigation, for six years Pavel headed Kept's (ex-KPMG) Tax and Legal, where he advised and defended oil and gas, industrial, pharmaceutical, and construction businesses in court. Pavel worked for the Pepeliaev Group for over ten years, heading the Far East, oil and gas and tax practices focusing mainly on major accounts operating in various industries. He served in the Russian Federal Tax Service for three years, heading the Legal Department and representing the Government in complex tax disputes.
Legislative, Scientific Activities and Membership in Associations
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Pavel is an expert of the Russian State Duma Committee on Energy.

He has contributed to:

  • drafting the Protocol to the Interstate Agreement setting out the legal conditions for implementing an oil and gas project
  • development a draft Federal Law introducing amendments to the Russian Tax Code (service risk agreement, management agreement)
  • developing a bill introducing amendments to the Russian Tax Code aimed to eliminate gaps in the taxation of oil and gas businesses operating in the Caspian Sea
  • developing draft amendments refining the tax treatment of new offshore fields, PSAs
  • developing a set of bills introducing amendments to various legislative instruments in order to improve the regulation of mining operations on the Russian Federation’s continental shelf, etc.
Education
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  • Faculty of Law, Far Eastern Law Institute, Russian Ministry of Internal Affairs
  • Faculty of Economics, Khabarovsk State University of Economics and Law
Languages
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Russian, English

Pavel advised:

a JV of a major Russian and international oil and gas company

entering into a RUB 100+ bln investment agreement with the Russian Federation

a major oil and gas business

during a RUB 50+ bln M&A transaction, including preparation of a tax model, structuring of entry, financing, return on investments and project withdrawal options

a major metallurgical business

in connection with a RUB 25 bln project for comprehensively analysing expenses to find the least risky cost-recognition solution for assessing taxable profit. The project also revealed RUB 1.7 bln in overpaid property taxes

a major oilfield service company in a dispute

over the applicable profit tax rate in connection with the Sakhalin 2 Project. Pavel succeeded not only in winning the legal dispute but also in changing the previous adverse 3-year court practice in the Russian Far East. Winning those proceedings also enabled two previously lost cases involving other international oilfield service and construction companies to be reheard on newly discovered facts and achieve a favourable settlement of a similar tax dispute at the pre-trial stage. Ultimately, Pavel helped the clients receive a tax refund or avoid tax claims totalling about RUB 2 bln. The outcome of the dispute was that the Sakhalin-2 Project contractors save about RUB 200 bln a year in taxes

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