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Portrait of Hayk Safaryan

Hayk Safaryan

Head of Customs

CMS Russia
Naberezhnaya Tower, block C
10 Presnenskaya Naberezhnaya
123112 Moscow
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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Memberships & Roles

  • CCI France Russie, Customs and Transport committee, Co-President
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  • 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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On­line gambling law and reg­u­la­tion in Rus­sia
Find out the new rules of the game for book­maker gambling in Rus­sia
Double tax­a­tion treat­ies
In this sec­tion of the Tax chapter of Do­ing busi­ness in Rus­sia, we out­line gen­er­al prin­ciples of double tax­a­tion treat­ies (“DTTs”) and give ex­amples of the tax rates ap­plic­able un­der sev­er­al DTTs to which Rus­sia is a sig­nat­ory.
In this sec­tion of the Tax chapter of Do­ing busi­ness in Rus­sia, we cov­er spe­cif­ic in­cent­ives avail­able to those in­vest­ing in the Rus­si­an eco­nomy.
Spe­cial tax re­gimes
In this sec­tion of the Tax chapter of Do­ing busi­ness in Rus­sia, we out­line three spe­cial tax re­gimes avail­able to cor­por­ate tax­pay­ers un­der cer­tain cir­cum­stances.
Tax­a­tion of in­di­vidu­als
In this sec­tion of the Tax chapter of Do­ing busi­ness in Rus­sia, we deal with in­come tax and in­di­vidu­al prop­erty tax.
Cor­por­ate tax­a­tion
In this sec­tion of the Tax chapter of Do­ing busi­ness in Rus­sia, we cov­er the cor­por­ate profits tax, VAT, ex­cise du­ties, the cor­por­ate prop­erty tax, payroll-re­lated levies, taxes on nat­ur­al re­sources, trans­port tax, the sales duty and state du­ties.
Tax sys­tem
In this chapter of Do­ing busi­ness in Rus­sia, we provide an out­line of the fol­low­ing as­pects:cor­por­ate tax­a­tiontax­a­tion of in­di­vidu­alsspe­cial tax re­gimestax in­cent­ivesdouble tax­a­tion treat­ies Gen­er­al ap­proach Re­cent de­vel­op­ments The most im­port­ant amend­ments to tax­a­tion laws over the last three years in­clude:Since 2019, for­eign com­pan­ies and for­eign in­ter­me­di­ar­ies provid­ing e-ser­vices are ob­liged to re­gister for VAT pur­poses in Rus­sia and pay taxes loc­ally, un­der cer­tain con­di­tions. This ob­lig­a­tion ap­plies to all types of cli­ents of such for­eign com­pan­ies (i.e. Rus­si­an leg­al en­tit­ies, in­di­vidu­al en­tre­pren­eurs and in­di­vidu­als).Spe­cial ad­min­is­trat­ive areas were cre­ated on Russky Is­land (Primor­sky Krai) and Ok­tyabrsky Is­land (Ka­lin­in­grad Re­gion). Res­id­ents of these areas who meet spe­cif­ic re­quire­ments can en­joy some tax be­ne­fits.Sig­ni­fic­ant tax be­ne­fits un­der cor­por­ate profits tax and in­sur­ance con­tri­bu­tions were in­tro­duced for ac­cred­ited IT com­pan­ies and de­velopers of elec­tron­ic com­pon­ents (provided they sat­is­fy cer­tain cri­ter­ia). At the same time, the scope of VAT ex­emp­tions on the dis­pos­al of rights to com­puter soft­ware and data­bases (which were equally ap­plied both by loc­al and for­eign com­pan­ies) has been ma­ter­i­ally re­duced.A pro­gress­ive per­son­al in­come tax scale for in­come re­ceived by Rus­si­an res­id­ents has been in­tro­duced. From 1 Janu­ary 2021, Rus­si­an tax res­id­ents’ in­come ex­ceed­ing RUB 5m (EUR 55,5551At the no­tion­al ex­change rate of RUB 90 = EUR 1, as used for con­veni­ence through­out this guide.foot­note)  is taxed at the rate of 15% in­stead of the pre­vi­ously ap­plic­able flat rate of 13%.Gen­er­al trans­fer pri­cing con­trol was ab­ol­ished for do­mest­ic in­tra­group op­er­a­tions (ex­cept in spe­cif­ic cases). Or­gan­isa­tions act­ive on the fin­an­cial mar­ket are now un­der an ob­lig­a­tion to col­lect fin­an­cial in­form­a­tion about their cus­tom­ers, as well as their cus­tom­ers’ be­ne­fi­ciar­ies and con­trolling per­sons, and to provide such in­form­a­tion to the tax au­thor­it­ies. If, at the re­quest of such an or­gan­isa­tion, a cus­tom­er, be­ne­fi­ciary or con­trolling per­son re­fuses to dis­close the re­quired in­form­a­tion, op­er­a­tions between the cus­tom­er and the or­gan­isa­tion must be sus­pen­ded.
CMS Rus­sia earns a re­cord num­ber of re­cog­ni­tions by Best Law­yers 2022
Strong re­cog­ni­tion by the rank­ing 32 CMS Rus­sia ex­perts have been se­lec­ted for in­clu­sion in­to the 2022 edi­tion of the Best Law­yers rank­ing. In total, we have earned 74 re­cog­ni­tions by the rank­ing :Ant­on...
Cus­toms reg­u­la­tions
This chapter of Do­ing busi­ness in Rus­sia mainly char­ac­ter­ises the cus­toms reg­u­la­tion in the Euras­i­an Eco­nom­ic Uni­on (the “EEU”) and gives gen­er­al prin­ciples ap­ply­ing to trade between EEU and non-EEU coun­tries.
CMS Rus­sia ranked in IFLR1000, World Tax and World Trans­fer Pri­cing 2021
The 2021 edi­tions of IFLR1000, the World Tax and World Trans­fer Pri­cing, op­er­at­ing with­in the pub­lish­ing house Eur­omoney In­sti­tu­tion­al In­vestor PLC, named CMS Rus­sia one of the best law firms in Rus­sia...
Do­ing busi­ness in Rus­sia 2020
As part of our un­der­tak­ing to cre­ate ad­ded value for cli­ents, our pro­fes­sion­als have put to­geth­er this in­tro­duct­ory guide to the Rus­si­an leg­al sys­tem and the prin­cip­al laws and reg­u­la­tions that are of in­terest to in­vestors in this chal­len­ging but op­por­tun­ity-full mar­ket. It is of course no sub­sti­tute for the ex­pert ad­vice tailored to your pro­ject that we will be pleased to provide to you on re­quest.Rus­si­an le­gis­la­tion is chan­ging rap­idly. Al­though this guide de­scribes the laws as of 1 Janu­ary 2020, please con­tact us to check that it re­mains up-to-date. We would also re­com­mend that you sub­scribe to our free on­line ser­vice CMS Law-Now through which you will re­ceive our leg­al and tax eAl­erts. Jean-François Mar­quaire (Man­aging Part­ner)Le­onid Zubar­ev (Seni­or Part­ner)
CMS Rus­sia earns 58 re­cog­ni­tions by Best Law­yers 2021
Strong re­cog­ni­tion by the rank­ing 26 CMS Rus­sia ex­perts have been se­lec­ted for in­clu­sion in­to the 2021 edi­tion of the Best Law­yers. In total, we have earned 58 re­cog­ni­tions by the rank­ing:Ant­on Bankovskiy...