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Tissot Dominique

Dominique Tissot

Partner
Head of Tax | Head of Energy Efficiency & Renewables

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

Dominique specialises in domestic and international tax. He has in-depth experience in project finance, complex cross-border M&A transactions and due diligences of Russian majors and international group of companies e.g. from the FMCG/Retail, Infrastructure, Construction, Automotive and Energy sectors.

He has assisted Russian and foreign companies on tax aspects related to major acquisitions, divestitures, business reorganisations and efficient holding structures for outbound/inbound investment and for manufacturing operations and distribution activities in Russia. 

Dominique has over 20 years' experience as a tax specialist. Prior to joining CMS Russia, Dominique worked for various Big4 and international law firms as a tax advisors and an international tax manager for a French energy major, where he was in charge of Russia, Germany and a number of Eastern European countries.

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Dominique Tissot advises on corporate tax, transfer pricing and international tax structuring. He is a French-qualified lawyer and a native French speaker, making him well placed to advise French clients operating in Russia.

Chambers Global

Relevant experience

  • A leading carmaker retail bank – assistance on all the aspects of a USD 130m Russian M&A transaction (with a planned total investment of about USD 450m), through a complex cross border structuring scheme involving two newly set up foreign JV companies on all aspects of the project (tax, corporate, commercial, regulatory, etc.) in all jurisdictions involved. We also represented jointly the interest of all project participants (i.e. including two other partners) on some specific matters e.g. Central Bank filing, EU merger notification
  • A worldwide leader from the aircraft industry – assistance in the set up a Joint-venture with a leading Russian aerospace company for the purpose of manufacturing a new type of aeroplane in Russia (EUR 100m + supply contracts). This project involved complex corporate, commercial, tax and customs cross-border advice linked to the choice of proper JV structure and localisation, due to regulatory/competition law constraints as well as tax and customs optimisation of cross-border supply contracts (R&D and spare parts) and plane assembling scheme in Russia
  • World leader in prepaid corporate service – assistance on all tax and legal aspects of an M&A transaction (acquisition of a Russian target): e.g. tax planning of the cross-border ownership structure; negotiation and drafting of corporate documents (SPA, SHA) 
  • The worldwide leader in electrical and digital building infrastructures – advice on all tax and legal aspects of this M&A transaction (transfer of business activities from various Russian regions in the region of Ulyanovsk). Our work also included the negotiation and drafting of an investment contract and corresponding tax incentives with the governor of the region, making amendments to regional and local tax legislation; drafting of all contractual and other arrangements (e.g. land lease, industrial lease, sale purchases contracts) 
  • The worldwide leader in the global dispensing systems industry – we provide to this US company, listed on the NYSE, going tax, customs and legal advice; assistance in the preparation of the transfer pricing documentation; we also advised on the strategy to formalise intragroup cost re-invoicing and elaborate the full set of supporting documents to secure the client’s tax position
  • A leader from the aerospace & defence industries - We provided complex tax advice the contemplated intragroup M&A/reorganisation (share deal with a subsequent downward merger, contract transfer optimisation); we also advised on various and complex tax issues e.g. customs (optimisation of the importation scheme for components and spare parts), corporate profits tax (e.g. transfer pricing (diagnostic/mapping of transactions), management fees, inventory valuation, intragroup cost allocation, optimisation of warranty/post-warranty equipment maintenance costs, optimisation of royalty payments, tax audits 
  • A leader in the habit and construction market - (ranked in the Top 100 Industrial Companies) – advising on the TP strategy for this major group of companies comprising numerous factories and other commercial entities in Russia, preparing the full pack of Russian transfer pricing documentation (Russia Country file) and the corresponding notifications to the tax authorities for all entities of the group in Russia.
  • Third-largest container shipping company worldwide – on-going support and assistance in the negotiations on tax and customs issues regarding various complex commercial contracts on oil products and marine fuel supply
  • A leading chain of supermarkets − tax reviews of all their Russian business activities (about 25 Russia−based companies and 15 branches) for the past three fiscal years for the purpose of documenting all key operational and capital expenditures to achieve expense recognition for profits tax purposes and VAT credit recovery.
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Education

  • 1998 –French Bar School, Admitted to the Bar
  • 1996 − Bourgogne University, LLM in International Business Law
  • 1995 − Lyon III University, LLM in European Business Law
  • 1994 − Lyon III University, English Law Diploma and Master's degree in Business Law with major in corporate taxation
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Memberships

  • French Foreign Trade Advisor (Comité National des Conseillers du Commerce Extérieur de la France)
  • Member of the Board of Directors of the Union of Enterprises for Energy Efficiency and Environmental Security
  • Member of the Board of Directors of the Franco-Russian Chamber of Commerce in Russia
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28 Oct 19
Do­ing busi­ness in Rus­sia 2019
11 Sep 19
Rus­si­a's tax ser­vice is­sues cla­ri­fic­a­tion on be­ne­fi­cial own­er­ship...
On 8 Au­gust 2019, the Fed­er­al Tax Ser­vice of Rus­sia is­sued a let­ter* cla­ri­fy­ing its po­s­i­tion in re­la­tion to the be­ne­fi­cial own­er­ship of hold­ing com­pan­ies. For­eign com­pan­ies re­ceiv­ing in­come from Rus­si­an...
28/06/2019
VAT for for­eign e-ser­vices pro­viders: the Rus­si­an tax...
Ja­pan­ese ver­sion
28 Jun 19
VAT for for­eign e-ser­vices pro­viders: the Rus­si­an tax au­thor­it­ies'...
The Rus­si­an tax au­thor­it­ies have is­sued a Let­ter* ac­cord­ing to which they will ac­cept the pay­ment of VAT by Rus­si­an pur­chasers of B2B e-ser­vices from for­eign sup­pli­ers. This will not how­ever re­lieve the...
24/05/2019
CMS Rus­sia earns 33 re­cog­ni­tions by Best Law­yers 2020
02 Oct 18
Rus­sia in­tro­duces sweep­ing tax changes
The Rus­si­an tax sys­tem is cur­rently un­der­go­ing ma­ter­i­al changes in dif­fer­ent spheres crys­tal­lised in a num­ber of new laws ad­op­ted dur­ing this sum­mer, in­clud­ing Fed­er­al law No. 302-FZ* and Fed­er­al law...
17/04/2019
The Leg­al 500 EMEA 2019 ranks CMS Rus­si­a's ex­perts...
22 Jun 18
With Rus­si­an re­new­ables on the rise, in­vestors search for op­por­tun­it­ies...
In­vest­ment op­por­tun­it­ies Rus­sia has the po­ten­tial to in­crease its use of all types of re­new­able en­ergy. His­tor­ic­ally, it has a well-de­veloped hy­dro­power sec­tor. Its bioen­ergy po­ten­tial is also sig­ni­fic­ant...
15/10/2018
Rus­sia in­tro­duces sweep­ing tax changes
Ja­pan­ese ver­sion
05 Jun 18
“Three-tier” trans­fer pri­cing doc­u­ment­a­tion e-formats ap­proved in...
The Rus­si­an Fed­er­al Tax Ser­vice has re­cently ap­proved the formats for fil­ing three-tier trans­fer pri­cing doc­u­ment­a­tion – spe­cific­ally, the fil­ing of no­ti­fic­a­tions of par­ti­cip­a­tion in mul­tina­tion­al groups...
Aug 2018
Rus­si­an re­new­ables mar­ket: in­vest­ment op­por­tun­it­ies...
23 May 18
New rules on VAT re­port­ing and pay­ment for for­eign com­pan­ies provid­ing...
For­eign com­pan­ies ren­der­ing e-ser­vices on the Rus­si­an B2B mar­ket will be sub­ject to new VAT re­gis­tra­tion, re­port­ing and pay­ment re­quire­ments from 1 Janu­ary 2019 un­der Law No. 335-FZ*. Back­ground As...