Russia

PwC Russia

White Square Office Center

Butyrsky Val 10

Moscow, 125047

Russian Federation

Tel: +7 (495) 967 6000

Fax: +7 (495) 967 6001

Email: alexakhina.raisa@ru.pwc.com

Website: www.pwc.ru/en

Raisa Alexakhina, PwC Russia, is a partner and the leader of tax dispute resolution and legal services in Russia. She has been providing tax and legal services since 1994 combining both industry and experience from the Big 4 firms. She is a frequent speaker on various tax controversy topics.

Over the course of her career, Raisa has led an extensive number of complicated tax litigation projects in a variety of industries. She has represented clients in more than 500 tax disputes at all levels, including Russian supreme and supreme commercial courts and achieved an exceedingly high rate of success in the process.

Raisa has earned a master's degree in law from Moscow State Law Academy and a PhD in financial law.

KPMG in Russia

Naberezhnaya Tower Complex

Block C 10 Presnenskaya Naberezhnaya

Moscow 123112

Russia

Tel: +7 812 3137300

Email: sdenisenko@kpmg.ru

Website: www.kpmg.com

Stanislav Denisenko has significant multidisciplinary experience in advising on various areas of law including tax and customs, currency, civil and labour law. Stanislav has impressive and extensive experience in representing interests of KPMG clients in a wide range of tax disputes at pre-litigation and litigation stages, including in supreme courts. His clients include major foreign and Russian companies engaged in various sectors of business.

His experience includes:

• Success in the Supreme Arbitration Court for a major developer at the commercial real estate market. Supported by the KPMG team headed by Stanislav, the client successfully challenged tax charges of more than RUB 500 million ($8.3 million). Notably, the client engaged KPMG after the courts of two instances had denied its claims twice;

• A tax dispute won for a major pharmaceutical company at all three court instances. The issue related to the deductibility of costs of lectures delivered to medical workers, and the tax in question exceeded RUB 100 million;

• A case won related to the deductibility of management fees for the services rendered by the group service centre for tax purposes in Russia. Despite the negative practice and low chances of winning, Stanislav managed to build up sustainable arguments, collect supporting documentation, and develop a strategy of presenting evidence, which enabled the company to challenge tax charges of more than approximately RUB 150 million in total and also escape the same tax claims in the course of further tax audits;

• Success for a leading car manufacturer regarding transfer pricing issues at the higher tax authority. The tax effect for the company exceeded RUB 100 million. Remarkably, the higher tax authority had supervised the entire tax audit process. However, he managed to convince it that the company's position was stronger;

• He helped a foreign pharmaceutical distributor reduce additional tax charges by a factor of 40 (from RUB 100 million to RUB 2.5 million) at the stage of considering tax audit materials; and

• A leading developer at the commercial real estate market managed to escape additional tax charges in the amount exceeding RUB 70 million at the pre-trial stage.

Stanislav graduated from St. Petersburg State University's law school and also has an advanced degree in engineering. He has been working with KPMG for 20 years. Before joining KPMG, he worked as the head of the legal department at a Russian bank.

KPMG in Russia

Naberezhnaya Tower Complex

Block C 10 Presnenskaya Naberezhnaya

Moscow 123112

Russia

Tel: +7 495 937 44 77

Email: aermolaev@kpmg.ru

Website: www.kpmg.com

Andrey Ermolaev joined KPMG from another Big 4 firm, where he was engaged in providing a wide range of tax management services, including tax disputes resolution for large Russian and international companies in consumer, industrial, oil and gas and financial sectors.

Andrey has extensive experience assisting companies at all stages of the tax audit, from the beginning of the tax audit to appeal, including representing companies' interests during tax control measures, preparation of objections and appeals. He has more than 300 successfully held arbitration court hearings in his portfolio.

In addition to dispute resolution work, Andrey's expertise also includes:

• Monitoring companies' activities for the periods potentially falling under the tax audit, identification and evaluation of potential tax risks associated with possible tax claims, and assistance in preparation of defence files;

• Organisation and conduction of meetings and negotiations with the chief of the Federal Tax Service of the Russian Federation, in particular with the control and legal departments of the federal tax service, in order to settle of the current tax disputes (under the current tax control measures), and its prolongation on the future periods;

• Organisation and conduction of meetings and negotiations with the chief of the Interregional Inspectorates for Major Taxpayers, including Interregional Inspectorates for Major Taxpayers No. 1 (oil producers), No. 2 (gas sector), No. 5 (iron and steel companies), No. 7 (telecommunications companies), No. 8 (machinery), No. 9 (banking sector), and tax audits and developing tax accounting methodologies; and

• Interaction with the government and executive authorities, including the Ministry of Finance, Ministry of Economic Development of the Russian Federation, Administration of the President of the Russian Federation.

Andrey has a degree in civil law from the Moscow State Law Academy and a second degree in financial management from the State University of Management.

PwC Russia

White Square Office Center

Butyrsky Val 10

Moscow, 125047

Russian Federation

Tel: +7 (495) 967 6087

Fax: +7 (495) 967 6001

Email: maria.mikhaylova@ru.pwc.com

Website: www.pwc.ru/en

Maria Makhaylova is a director in PwC's tax dispute resolution group.

She has extensive experience in tax matters and has represented clients in more than 50 cases over the past three years. She has represented major Russian and multinational enterprises in a broad range of tax cases, from pre-trial dispute resolution through to all tax litigation stages. Maria's professional expertise also includes transfer pricing claims, VAT and profit tax disputes, customs disputes and many other practical aspects of tax and customs law.

She provided complex tax and legal support to a leading Russian food retailer for the creation of one of Russia's largest consolidated taxpayer groups.

Maria regularly participates in external and internal tax resolution seminars as expert and speaker.

Schekin and Partners

World Trade Center

Krasnopresnenskaya Embankment, 12

Moscow, 123610

Russia

Tel: +7 495 984-63-01

Email: info@schekinlaw.ru

Website: www.schekinlaw.ru

Denis Schekin is a managing partner at Schekin & Partners in Moscow.

He works on tax disputes and tax audit support, tax structuring and risk assessment, and transfer pricing. Denis specialises in tax law, including tax disputes and tax consulting.

Denis has advised companies and handled tax disputes since 1995. He has represented Russian and multinational clients in court, challenging additional tax assessments worth hundreds of billions of rubles.

According to the Best Lawyers, Chambers Europe, the Global Legal Experts, Tax Directors Handbook, European Legal Experts, and others, Denis is ranked as one of the top Russian tax specialists.

Denis is the author of books and publications on tax and is one of the most prominent speakers on tax topics.

Denis graduated from the Law Department of Krasnoyarsk State University in 1997, and further in 2001 became a PhD of Judicial Sciences. Denis is also a member of the Federal Chamber of Lawyers of the Russian Federation.

Schekin & Partners specialises in tax, commercial law and various types of litigation, providing superior services with depth of knowledge and wealth of experience. The firm offers legal advice to leading Russian and multinational enterprises in oil and gas, metals, food products, automotive, construction, transportation, IT, banking, wholesale and retail and other industries. The professionals of Schekin & Partners follow a rigorous programme of professional study, read all key publications on tax, civil law, court rulings and official guidance. The firm leverages its established connections with leading Russian universities to obtain expert opinion on the most complex problems relating to any branch of law.

KPMG in Russia

Naberezhnaya Tower Complex

Block C 10 Presnenskaya Naberezhnaya

Moscow 123112

Russia

Tel: +7 495 937 44 77

Email: azykov@kpmg.ru

Website: www.kpmg.com

Anton Zykov has been representing clients in litigation against the tax authorities since 2000, and has been in arbitration courts since 2001. Anton has defended the interests of taxpayers for more than 15 years, and has supervised the work of lawyers in more than 70 legal disputes with the tax authorities. He also advises clients on transactions where the tax treatment is ambiguous and the provisions of tax law that are controversial have been applied.

In addition to his work as an attorney, Anton has testified as an expert witness on issues of Russian law before the London Court of International Arbitration tribunal and has experience of preparing expert opinions for litigation and arbitration proceedings.

Anton has represented companies from a number of industries, including oil and gas, construction and construction materials, professional services, agriculture, the food industry, real estate, financial services, industrial and consumer equipment.

The team of lawyers lead by Anton has successfully defended taxpayers in disputes with the tax authorities in Arkhangelsk, Vladimir, Moscow and Moscow Region, Mari El, Nizhny Novgorod, Omsk, Perm, Pskov, Rostov-on-Don, Samara, St. Petersburg, Tomsk, Tyumen and Yuzhno-Sakhalinsk.

Anton joined KPMG in 2008. He is listed by professional rating groups such as Chambers & Partners, Legal500, and by International Tax Review's Tax Controversy Leaders guide.

Anton graduated from Voronezh State University in 2000 with a degree in law (cum laude). He was admitted to practice law in Russia by the Russian Bar Association in 2003.

Anton now works for Deloitte

5 Lesnaya Street, Moscow, 125047, Russia

Tel: +7 (495) 787 06 00 ext. 1778

Fax: +7 (495) 787 06 01

Email: azykov@deloitte.ru

Website: www.deloitte.ru