Artem Toropov is a senior associate in Baker McKenzie’s Moscow office. Artem focuses on the areas of international tax planning, corporate restructurings, and tax structuring of M&A deals. He is experienced in advising Russian ultra high net worth individuals, families and family offices on the issues of asset protection, trust structuring, succession and residency planning. He also advises on matters of "deoffshorization" compliance and Russian currency control (RCC) compliance in relation to foreign accounts, personal holding companies, trusts and foundations (wealth management).
Artem is the member of the Firm's European Wealth Management Steering Committee. He is also an associate professor of tax law at the National Research University Higher School of Economics.
Representative Legal Matters
- Advised a global trust company on the set-up of a disclosed and CFC compliant family trust settled by an ultra high net worth Russian family for the benefit of their multiple children and elderly parents, taxation of the trust under the Russian CFC rules, tax-efficient transfer of assets to the trust, new Russian tax exemptions related to distributions to family members from trusts.
- Advised a leading financial services company on the set-up of a disclosed and CFC compliant family trust settled by the same ultra high net worth Russian family.
- Advised a major trust company on the tailoring of the trust documentation for foreign trusts of Russian resident high net worth clients and taxation of foreign trusts of Russian residents under the Russian CFC rules.
- Advised an independent asset manager with clients in Asia, Europe and Latin America, on the taxation of a foreign trust of a Russian high net worth family under the Russian CFC rules.
- Advised high net worth individuals on the mandatory and voluntary disclosure of their foreign assets to Russian tax authorities (voluntary disclosure programme), the CFC status of foreign trusts and other personal holding vehicles, the restructuring of personal and business assets, as well as on relocation to the UK, Switzerland and Monaco.
- Consulted a Swiss private wealth management company serving high net worth individuals on application of Russian currency control rules, repatriation of funds and taxation of foreign portfolio investment income of Russian individuals.
- Advised foreign financial institutions on the Russian tax and disclosure implications of their products offered to Russian high net worth individuals, including the CFC implications and the disclosure of such products to Russian tax authorities.
- Advised foreign financial institutions on the matters of automatic exchange of information under Russian domestic legislation (Law No. 173-FZ, "Russian FATCA").
- Advised foreign financial institutions on the Russian tax implications of using fiduciary deposits and loans offered to Russian clients in light of TP (transfer pricing) rules, BO (beneficial ownership) rules, thin capitalization rules and CFC rules.
- Advised foreign trust companies on matters related to the application of CFC exemptions for disclosed irrevocable discretionary trusts.
- Star Associate, Chambers High Net Worth, 2018-2020
- Rising star, Legal 500 EMEA, 2018-2020
- Ones-to-Watch in Private Client Global Elite directory, Legal Week
Professional Associations and Memberships
- Association of European Businesses (AEB), Tax Committee - Member
- International Fiscal Association (IFA), Russia branch - Member
- International Bar Association (IBA) – Private Client Tax Committee, Member
- Society of Trust and Estate Practitioners (STEP) – Affiliate Member
- Russia (2007)
- National Research University Higher School of Economics (Law with honors) (2007)
- Moscow State University (Foreign Languanges Faculty, Degree in Translation)
Co-author, "Russia, India, and Others Revise Tax Treaties to Fund COVID Relief," Baker McKenzie Private Wealth Newsletter, December 2020
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, "Individuals can Voluntarily Qualify as Tax Residents in Only 90 Days in 2020," Baker McKenzie InsightPlus, August 2020
Co-author, "Extension of Filing Deadline for Cash Flow Statements for Individual Foreign Accounts," Baker McKenzie InsightPlus, June 2020
Co-author, "COVID-19 - Government Extends Deadline for Filing 2019 Individual Income Tax Returns Until 30 July 2020," Baker McKenzie InsightPlus, April 2020
Co-author, "Softening Currency Control Regulations for Russians Living Abroad," Lexology, 1 December 2017