Hayk Safaryan

Partner
Head of Customs

CMS Russia
Naberezhnaya Tower, block C
Presnenskaya Naberezhnaya 10
123112 Moscow
Russia
Languages English, French, Armenian

Hayk’s practice encompasses all areas of domestic and international corporate tax planning. Hayk has an excellent track record in advising on the tax implications of M&A, JV, corporate restructuring and reorganisations, financing, real estate and securities transactions as well as in carrying out tax due diligence. Hayk has been practising and advising on tax issues with CMS Russia since 2002.

Hayk assists clients in their relations with the authorities during tax audits. In addition to purely advisory work, he has been involved in tax dispute resolution. In particular, he has extensive experience in challenging tax audit conclusions, in which he either secured pre-trial settlement or successfully represented clients in Russian courts of all levels.

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Relevant experience

  • A leading French luxury company assisting in connection with tax audits and successfully challenging the tax audit conclusions for two Russian companies of the group, including developing legal argumentation regarding various VAT and corporate income tax issues and significantly reducing tax authorities’ claims at pre-trial stage.
  • A leading Swiss pharmaceutical company assisting in relation to ongoing tax, customs and legal issues regarding regulatory and licensing issues, clinical trials, distribution models, parallel imports and stock management advising on transfer pricing issues, including implementing the company’s new transfer pricing policy.
  • A leading international insurance company – carrying out tax due diligence and assessing tax risks.
  • A global drilling services provider – advising on the company’s tax and customs obligations in Russia arising in connection with activities performed on the Russian continental shelf under a bareboat charter agreement with a Russian client; assessing  tax and customs risks, providing  risk mitigation solutions, advising on the contract structure.
  • A leading international cosmetics company – consulting in connection with a long standing project involving reviewing various cost categories specific to the Russian consumer goods industry (such as promotion and marketing expenses, relocation expenses, POSM, samples, testers, PLV, etc.), making detailed recommendations and drafting proper supporting documents (acts, contracts, etc.) for each category of cost.
  • A leading French retail company − advising on various tax and customs issues, as well as drafting the necessary contractual arrangements with suppliers/sub-contractors.
  • A leader in the technical textiles sector – advising on legal and tax issues for the on-shore and off-shore structuring of an industrial joint project with Russian partners to set up a carbon fibre fabrics production in Russia.
  • A global manufacturer of construction equipment – advising on various legal, tax and customs aspects connected with the setting-up of manufacturing facilities in Russia, such as,the “made in Russia” concept, the public procurement system, procurement to state owned companies, the industrial assembly regime, the recycling fee, the tax and customs regime of special economic zones, regional tax incentives.
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Education

  • 2010 - Moscow State Academy of Law, Law faculty, Master in law
  • 2002 - Moscow State University, Economics faculty, Master in international management
  • 2001 - Aix-Marseille III University, Law faculty, Master in public economic law
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Memberships

  • CCI France Russie, Customs and Transport committee, Co-President
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