Arseny Seidov is a partner in the Tax Practice Group of Baker McKenzie's Moscow office. Prior to joining Baker McKenzie in 2003, he worked at a Russian audit firm, a major Swiss bank and the Moscow office of a major US law firm. Arseny is consistently recommended by Chambers Global, Chambers Europe and International Tax Review.
Arseny leads the Working Group on Taxation of E-commerce at the Association of European Businesses and co-chairs the tax subgroup of the Innovation Working Group at the US-Russia Bilateral Presidential Commission. He also acts as Russia representative of Baker McKenzie's Digital Economy Group headquartered in Silicon Valley.
Arseny is a frequent speaker at leading tax and IT-related conferences in Russia and abroad. Since 2007, he has been a visiting professor of international tax at the Moscow State University for International Relations.
Arseny has extensive experience in general tax planning and restructuring. He also provides full-scope direct tax and VAT advice as well as tax advice on IP matters, M&A deals and corporate reorganizations. He also advises on transfer pricing and customs valuation issues and handles tax litigation.
Arseny primarily assists multinationals in developing tax-efficient structures for doing business in Russia and in resolving sophisticated tax matters. He focuses on a wide range of industries, including FMCG, pharmaceuticals, mass media and entertainment, real estate and construction, and hotels and restaurants. Arseny has extensive experience on the taxation and regulation of IT and communications industry, and digital economy in general. He regularly advises clients from the e-commerce, cloud computing and games sectors.
Representative Legal Matters
Advised a broad range of multinational companies on Russian tax issues in M&A deals, negotiation of tax-related provisions in SPAs, organization of pre-acquisition tax due diligences of Russian target companies in various industries.
Advised clients on software licensing matters and SaaS, Paas and IaaS models, on newly established VAT regime on taxation of electronically supplied services, and ringfencing of sales activities in connection with long-term, server-based permanent establishment exposure.
Advised several international and domestic developers of MMO games on restructuring their operations in Russia and the CIS; substance-based IP migration overseas and EULA adaptation procuring optimal VAT treatment, subject to newly-introduced rules on beneficial ownership, tax residency rules based on place of effective management and CFC legislation; and improvement of monetization processes for games through payment terminals, e-wallets / e-money, scratch cards, etc., with simultaneous compliance with statutory requirements on individual payer identification and personal data localization.
Advised major mass media companies on domestic and cross-border tax restructuring of their Russian operations in connection with legislative changes restricting foreign ownership in local media companies and on structuring their domestic transactions, including with advertising agencies and local television companies with respect to placement of advertising on paid TV channels.
Advised a major medical technology company on a complex and multiurisdictional tax structuring of a joint venture for onshore manufacturing and distribution of medical devices produced using world-class technology and used in sophisticated surgical procedures.
Advised several major offshore contractors in the global oil and gas industry on various Russian tax and customs law matters related to the design, transportation and installation of deep-water facilities on the Russian continental shelf.
Advised clients on establishing manufacturing operations (including toll and contract manufacturing) through tax-efficient structures, subject to regional and local tax exemptions and benefits under investment agreements and/or special tax regimes.
Advised Brown-Forman Corporation on a complex project for the distribution of Brown-Forman’s portfolio of beverage brands in the Russian market through Coca-Cola Hellenic Bottling Company Eurasia, subject to various tax, customs, and regulatory restrictions.
Advised Costa Crociere S.p.A. on the tax aspects of an agreement with Rosmorport, a state-owned company created for the development of Russian marine transport, for a time charter of the Grand Holiday cruise ship used as a floating hotel during the 2014 Winter Olympics in Sochi.
Advised Amsted Rail, the world’s leading manufacturer of undercarriage and end-of-car railcar components, on its joint venture with United Wagon Company. The joint venture was intended to introduce the latest technology in heavy haul railway components into the freight railroading market in Russia, the CIS and other countries. Baker McKenzie advised Amsted Rail on all aspects of the transaction, including IP, corporate and M&A, antitrust and tax matters.
Professional Associations and Memberships
- American Chamber of Commerce - Head of Working Group on Taxation of Digital Economy
- Association of European Businesses - Head of Working Group on Taxation of E-Commerce
- US-Russia Bilateral Presidential Commission - Innovation Working Group - Co-Chair of Tax Subgroup
- International Fiscal Association - Russia branch
- Russia (2001)
- London Business School (MBA Global Executive Program) (2013)
- Columbia Business School (MBA Global Executive Program) (2013)
- New York University School of Law (LLM International Taxation) (2007)
- Diplomatic Academy of the Ministry of Foreign Affairs of Russia (PhD International Law) (2004)
- Moscow State Institute of International Relations (MGIMO University) (Specialization Degree Financial Law) (2002)
- Moscow State Institute of International Relations (MGIMO University) (LLB) (2001)