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 has been consistently recommended by Chambers Global, Chambers Europe, Legal 500 and International Tax Review among leading tax lawyers in Russia.
Arseny Seidov is a member of the Board of Directors of the American Chamber of Commerce in Russia. Arseny heads the Working Group on Taxation of E-commerce at the Association of European Businesses, the Working Group on Taxation of Digital Economy at the American Chamber of Commerce and previously headed the tax subgroup of the Innovation Working Group of the US-Russia Bilateral Presidential Commission. He also acts as Russia representative of Baker McKenzie's Digital Economy Group headquartered in Silicon Valley and a member of Baker McKenzie's VAT Steering Committee for the EMEA region.
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 law at the Moscow State Institute of International Relations (MGIMO University). He has authored over 40 publications.
Arseny has extensive experience in general tax planning and restructuring. He provides full-scope direct tax and VAT advice and tax advice on IP-related matters, M&A deals and corporate reorganizations. He also advises on transfer pricing and customs valuation issues and handles tax litigation.
Arseny focuses on developing tax-efficient structures for doing business in Russia. His tax expertise captures various industries, ranging from digital economy, e-commerce, cloud computing and gaming, as his core industry areas, to FMCG, healthcare, mass media and entertainment.
Representative Legal Matters
Developed customized structures for a large number of nonresident companies aimed at tax-efficient compliance with 2019 Russian VAT regime on B2B ESS and at minimum disruption of ongoing business operations.
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 outbound IP migration and EULA adaptation with optimal VAT treatment, subject to newly-introduced rules on beneficial ownership, tax residency rules based on place of effective management and CFC legislation; provided tax advice aimed at improvement of games monetization 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 multijurisdictional 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 NovaWind, the division of State Atomic Energy Corporation Rosatom responsible for Russia’s renewable energy program, on its joint venture with Dutch wind turbine manufacturer Lagerwey.
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.
Professional Associations and Memberships
- American Chamber of Commerce, Russia – Member, Board of Directors
- 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 – previously headed the Tax Subgroup
- International Fiscal Association, Russia branch
- Russia representative of Baker McKenzie's Digital Economy Group headquartered in Silicon Valley
- Member of Baker McKenzie's VAT Steering Committee for the EMEA region
- 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)
- Author, "Introduction of Physical Presence Requirements for Foreign Tech Companies - How to Comply with Minimum Tax Exposure?", Baker McKenzie InsightPlus, September 2021
- Co-author, "Multijurisdiction: CIS Countries Introduce New Rules on Taxation of Digital Services," Lexology, 12 July 2021
- Author, "Russia Radically Changes Tax Landscape for Software Companies," Bloomberg Tax, 24 February 2021
- Co-author, "Russia: Wealthy Russian residents may opt to pay individual income tax on fixed CFC profits," Baker McKenzie InsightPlus, 29 October 2020
- Co-author, "Russia: New protocol to Russia-Cyprus tax treaty increases tax rates," Baker McKenzie InsightPlus, 16 September 2020
- Co-author, "Russia Ready to Withdraw From Tax Treaty with Cyprus," Baker McKenzie InsightPlus, August 2020