Russian Tax Lawyer: Tax Disputes and Criminal Risk
A Russian tax dispute rarely begins with litigation. It usually starts with an audit, an assessment, questions about particular transactions or documents and a growing disagreement about what actually happened, and only later develops into an administrative challenge or proceedings before a Russian commercial court.
As a Russian tax lawyer, I can deal with the tax dispute itself while also looking at the criminal risk that may arise from the same facts, because the documents used to challenge an assessment, the explanations given about a transaction and the role attributed to a director may later matter far beyond the tax proceedings. I prefer to see the whole problem before the different parts of it begin moving in different directions, because a position that looks perfectly reasonable in a tax appeal should not be allowed to create an avoidable problem for the person whose decisions may later be examined by law-enforcement authorities.
As a Russian tax lawyer, I can deal with the tax dispute itself while also looking at the criminal risk that may arise from the same facts, because the documents used to challenge an assessment, the explanations given about a transaction and the role attributed to a director may later matter far beyond the tax proceedings. I prefer to see the whole problem before the different parts of it begin moving in different directions, because a position that looks perfectly reasonable in a tax appeal should not be allowed to create an avoidable problem for the person whose decisions may later be examined by law-enforcement authorities.
When a Russian tax dispute lawyer may be needed
You may need advice after a tax audit report or decision, when preparing an administrative challenge, before proceedings in a Russian commercial court or once litigation has already begun and you need to understand whether the existing position should be maintained, strengthened or reconsidered.
I work on the business side of the dispute, reviewing the assessment, the transactions in question, the supporting documents, the arguments already submitted and the evidence relied upon by the tax authority, and I can prepare the legal position and procedural documents and conduct the agreed stages of the litigation.
Where the same facts may also create personal criminal exposure, I look separately at who actually made the decisions, who prepared and signed the reporting, what authority the director or other individuals had and what conduct may ultimately be attributed to them personally.
I work on the business side of the dispute, reviewing the assessment, the transactions in question, the supporting documents, the arguments already submitted and the evidence relied upon by the tax authority, and I can prepare the legal position and procedural documents and conduct the agreed stages of the litigation.
Where the same facts may also create personal criminal exposure, I look separately at who actually made the decisions, who prepared and signed the reporting, what authority the director or other individuals had and what conduct may ultimately be attributed to them personally.
What I do
I review the tax assessment and evidence
I start with the substance of the matter rather than isolated phrases in the authority’s decision, which means reviewing the assessment, calculations, reporting, transaction documents, correspondence and the evidence on which the authority has relied.
I prepare challenges to tax authority decisions
Depending on the stage of the matter, this may include objections, an administrative appeal, additional written submissions and other documents required to challenge the authority’s conclusions in a coherent way.
I represent clients before Russian commercial courts
I prepare the application, written submissions, responses, evidence and other procedural documents and can conduct the matter through the agreed stages of the proceedings.
If a particular procedural step requires somebody to be physically present, a local representative can be involved while I remain responsible for the substantive position and overall strategy; in other cases participation may be possible remotely where the court grants the relevant application, has the necessary technical facilities and the remote-identification requirements can be satisfied.
A substantial part of the preparation, document review and filing can in any event be handled remotely.
I assess criminal tax risk
Where the dispute begins to raise questions about the personal position of a director, owner, accountant or another individual, I separately assess the criminal-law implications and whether the position already taken in the tax proceedings is consistent with a possible future defence.
I start with the substance of the matter rather than isolated phrases in the authority’s decision, which means reviewing the assessment, calculations, reporting, transaction documents, correspondence and the evidence on which the authority has relied.
I prepare challenges to tax authority decisions
Depending on the stage of the matter, this may include objections, an administrative appeal, additional written submissions and other documents required to challenge the authority’s conclusions in a coherent way.
I represent clients before Russian commercial courts
I prepare the application, written submissions, responses, evidence and other procedural documents and can conduct the matter through the agreed stages of the proceedings.
If a particular procedural step requires somebody to be physically present, a local representative can be involved while I remain responsible for the substantive position and overall strategy; in other cases participation may be possible remotely where the court grants the relevant application, has the necessary technical facilities and the remote-identification requirements can be satisfied.
A substantial part of the preparation, document review and filing can in any event be handled remotely.
I assess criminal tax risk
Where the dispute begins to raise questions about the personal position of a director, owner, accountant or another individual, I separately assess the criminal-law implications and whether the position already taken in the tax proceedings is consistent with a possible future defence.
The tax dispute and criminal defence should not develop separately
The same transaction may first appear in an administrative tax challenge, then in proceedings before a commercial court and later in a criminal inquiry, and by that stage statements about what happened, who made the decision and what particular documents mean may already have been repeated several times.
Sometimes the position taken in the tax dispute reduces the criminal risk as well, but there are also situations where an argument that is useful for challenging the assessment needs to be considered much more carefully before it is repeated on behalf of a particular director or owner. For that reason, I prefer to consider the tax and criminal aspects together before the client is forced to reconcile two positions that have already been built independently.
Sometimes the position taken in the tax dispute reduces the criminal risk as well, but there are also situations where an argument that is useful for challenging the assessment needs to be considered much more carefully before it is repeated on behalf of a particular director or owner. For that reason, I prefer to consider the tax and criminal aspects together before the client is forced to reconcile two positions that have already been built independently.
If another tax adviser or lawyer is already involved
There is no automatic reason to replace them. I can become involved for a Second Legal Opinion, review the existing position and documents, assess the litigation or criminal-law risk and then leave the client to decide whether any further work is needed.
For international businesses this is often the most practical model, because the company may already have accountants, tax advisers or an internal legal team who know the business well, while what is missing is an independent Russian-law view of the dispute, the litigation strategy or the director’s personal exposure.
For international businesses this is often the most practical model, because the company may already have accountants, tax advisers or an internal legal team who know the business well, while what is missing is an independent Russian-law view of the dispute, the litigation strategy or the director’s personal exposure.
If the client or director is outside Russia
A foreign director may have signed Russian tax reporting prepared by a local accounting team, a parent company may be dealing with an assessment involving its Russian subsidiary, or a former director may already have left Russia by the time the authorities begin examining periods during which that person managed the company.
The initial work can usually be done remotely: I can review the Russian tax and corporate documents, reconstruct the chronology, identify which decisions and signatures matter and determine what requires immediate attention before anybody makes assumptions about travel or personal exposure.
Where a power of attorney is issued outside Russia, the formal requirements depend on the country of issue and on the purpose for which the document will be used. Where the group already has tax, accounting or compliance advisers, I do not need to duplicate their work; the Russian litigation and criminal-law position can be coordinated with the existing team.
Paying from outside Russia
Payment arrangements are agreed before work begins, taking into account the client’s country and the lawful payment methods available at the time.
The initial work can usually be done remotely: I can review the Russian tax and corporate documents, reconstruct the chronology, identify which decisions and signatures matter and determine what requires immediate attention before anybody makes assumptions about travel or personal exposure.
Where a power of attorney is issued outside Russia, the formal requirements depend on the country of issue and on the purpose for which the document will be used. Where the group already has tax, accounting or compliance advisers, I do not need to duplicate their work; the Russian litigation and criminal-law position can be coordinated with the existing team.
Paying from outside Russia
Payment arrangements are agreed before work begins, taking into account the client’s country and the lawful payment methods available at the time.
Why advocate status matters
Olga Sverchkova is a practising Russian advocate, Advocate Registry No. 47/825, Leningrad Region Bar Association, with more than twenty years of legal and advocacy practice.
I act for businesses in tax disputes, including challenges to tax authority decisions and proceedings before Russian commercial courts, while paying particular attention to the point at which a dispute about an assessment begins to create personal risk for a director or another individual. In an ordinary tax dispute, advocate status is not a substitute for tax and litigation expertise, but the distinction becomes important when the matter develops a criminal dimension.
A tax adviser or another lawyer may continue handling the tax side of the matter, but that role does not by itself make them defence counsel for a suspect or accused, and once personal criminal liability is being examined the matter requires more than an argument about the amount of tax.
I act for businesses in tax disputes, including challenges to tax authority decisions and proceedings before Russian commercial courts, while paying particular attention to the point at which a dispute about an assessment begins to create personal risk for a director or another individual. In an ordinary tax dispute, advocate status is not a substitute for tax and litigation expertise, but the distinction becomes important when the matter develops a criminal dimension.
A tax adviser or another lawyer may continue handling the tax side of the matter, but that role does not by itself make them defence counsel for a suspect or accused, and once personal criminal liability is being examined the matter requires more than an argument about the amount of tax.
Fees
Consultation from RUB 15,000
Initial review of the dispute, documents and possible next steps.
Strategic analysis from RUB 50,000
Detailed review of the tax position, prospects of challenge, litigation strategy and any related criminal-law risk.
Further legal work from RUB 100,000
The scope is agreed separately and may include a challenge to the tax authority’s decision, commercial court proceedings, procedural documents, a second opinion or criminal-law work connected with the same matter.
Common questions
Can you handle only the challenge to the tax authority’s decision?
Yes. The scope can be limited to the tax dispute if no criminal-law work is required.
Can a Russian tax case be handled remotely?
A substantial part of it can. Document review, preparation and filing can be handled remotely, while a local representative can be involved if a particular step requires physical attendance. Remote participation in a hearing depends on the court and the applicable procedural arrangements.
I already have tax advisers. Do I need to replace them?
No. They can continue handling the work they already know, while I deal with the agreed litigation work, provide an independent review or assess the criminal-law dimension.
Can I instruct you only for a Second Legal Opinion?
Yes. An independent review of the documents and existing strategy can be a standalone service.
Do you handle criminal cases involving Russian tax offences?
Yes, where the tax issue creates criminal exposure or has already become part of criminal proceedings.
If a Russian tax dispute has already started
For an initial review, it is useful to collect the tax audit report and decision, the calculation of the additional assessment, reporting and transaction documents for the relevant period, any administrative appeal or court documents already filed and, if law-enforcement authorities have already become involved, the procedural materials received from them.
Once those documents are considered together, it is usually much easier to see not only how the tax dispute should be handled, but also whether there is a parallel criminal risk that needs to be addressed before the two positions begin to diverge.
Legal information reviewed as of 27 September 2026. This page provides general information and does not constitute individual legal advice. The scope of work and strategy depend on the documents, procedural stage and circumstances of the particular matter.