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Valentina Semenova

Counsel, attorney — Tax Advise and Disputes
valentina.semenova@bgplaw.com
Valentina specialises in tax advising, tax disputes and rule-making. She has profound expertise and remarkable experience in providing advice on assessing profit tax, VAT, corporate property tax and mineral extraction tax. Valentina specialises in conducting tax reviews, developing and implementing tax compliance systems, applying for preferential tax treatment and benefits, and developing guidelines for tax purposes.

She provides useful support during tax audits, represents clients in pre-trial negotiations involving tax authorities, including when entering into settlement agreements, and defends companies challenging tax claims in court.

She advises on the specifics of international taxation, including application of the beneficial owner concept and CFC.

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Pravo-300
Past Experience
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Before joining BGP Litigation, Valentina was a member of the Kept (ex-KPMG) dispute settlement team and the Pepeliaev Group tax advice and dispute team, where she advised and represented oil and gas, mining, industrial, pharmaceutical, construction, transport and FMCG companies in court
Legislative, Scientific Activities and Membership in Associations
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  • Development of a draft Federal Law amending the Russian Tax Code to eliminate unequal tax treatment of organisations when handling bad debts
  • Development of a bill introducing amendments to the Russian Tax Code aimed at closing gaps in the taxation of oil and gas businesses
  • Other bills for eliminating inconsistencies between Russian laws dealing with taxes and levies and other laws of the Russian Federation
Education
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  • Faculty of Law, HSE University
  • Faculty of Economics, All-Russia State Tax Academy, Russian Ministry of Finance
Languages
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Russian, English

Valentina advised:

a major mining company

in connection with a tax dispute over collection RUB 800+ mln in taxes resulting from the tax authority re-adjusting by-product sale revenues

a major mining company

during pre-trial settlement of a dispute over additional VAT assessment in connection with alleged receipt of an unjustified tax benefit when purchasing services from an unconscientious counterparty. Thanks to a settlement agreement being reached at the pre-trial stage, the total VAT claims were reduced by more than RUB 870 mln

a major manufacturing company

in connection with an extra-judicial challenge to additionally assessed profit tax and VAT for parent company services, including preparation of the requisite evidence and holding negotiations with inferior and superior tax authorities, making it possible to have the additionally assessed taxes reduced by more than RUB 300 mln

a major mining company

in challenging the findings of off-site tax audits of VAT and mineral extraction tax returns, including participation in the tax authority's expert review, successful refutation of two expert opinions, participation in negotiations with the tax authority. The outcome was a settlement agreement allowing the client to avoid high additional charges

a major construction company

in connection with pre-trial settlement of a dispute over potential additional assessment of VAT and transaction tax relating to implementation of investment contracts; this allowed the client to avoid additional charges of more than RUB 900 mln

a major metallurgical company

in connection with a comprehensive project for determining the recording procedure (for a period of over ten years) for historical costs incurred in developing a major Russian copper ore deposit, including drafting applications to the Russian Ministry of Finance and assisting in obtaining clarifications on how to have the incurred costs recognised

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