Kirill Vikulov is a partner in the Tax law practice group of Baker McKenzie’s Moscow Office. He has extensive experience in advising Russian and multinational clients on a wide range of complex tax issues, including M&A deals, joint ventures, international holding and financing structures, and various financial and capital markets transactions. Prior to joining the Firm in 2007 Kirill Vikulov worked as a tax consultant in the international tax structuring department of an international audit company. Kirill is also a visiting professor of international tax law at MGIMO.
Tax planning and restructuring for corporate and private clients, tax advice for M&A and corporate reorganizations, wealth management.
Representative Legal Matters
- Advised PJSC KOKS in connection with the issuance of new USD 350 million 5.90% Notes due 2025 by IMH Capital D.A.C. under Rule 144A / Reg S. Tax structuring of the transaction, providing withholding tax opinion for various payments including review of the specifics of the Russian beneficial ownership rules.Financing transaction, which is reviewed by international rating agency clearly indicating strong reputation of the tax practice.
- Advised a Russian oil processing company on various direct and indirect tax issues, including recent changes in the Russian excise taxation for oil refineries.
- Advised Evraz Group in connection with taxation of the public holding company.
- Tax advice to multinational shipping line on transactional documents, tax structuring advice with regard to change of a holding structure; a part of regional restructuring and streamlining of the holding structure (including the analysis under the Russian Tax Code and under the applicable double tax treaties); full support of the transaction, preparing transaction documents and assisting in the execution process.
- Advised a Russian oil processing company in connection with concluding an agreement on modernization of processing assets with the Ministry of Energy of the Russian Federation. Advised the Russian company on various direct and indirect tax issues, including excise taxes that were critical for the transaction.
- Advised the Borrower, Joint Stock Company "KOKS", on legal and tax issues in connection with a tender offer and an offering of USD 500 million 7.5% LPNs due in 2022 pursuant to Regulation S and Rule 144A. Tax structuring of the transaction, providing withholding tax opinion for various payments including review of the specifics of the Russian beneficial ownership rules.
- Advised on tax structuring and various tax issues in M&A deals in oil & gas and other industries.
- Advised a major international oil and gas company in structuring a series of multi-billion dollar projects in Russia, including advice on and negotiation of tax-related provisions in SPA, joint venture and other agreements and transaction documents.
- Advised Russian and foreign groups on setting up tax-efficient holding, financing and management structures in the oil and gas, industrial manufacturing, consumer products and retail, real estate, pharmaceuticals, IT and financial services industries.
- Advised on intercompany restructurings for major Russian and foreign groups in view of the recent developments in the Russian so-called "deoffshorization" legislation (i.e., controlled foreign companies rules, beneficial ownership and corporate tax residency based on effective management and control tests) and court practice on thin-capitalisation.
- Next Generation Partner, Legal 500 EMEA 2019-2020
Professional Associations and Memberships
- American Chamber of Commerce (AmCham) - Tax Committee, Co-chair
- Advisory Board of the Federal Tax Service of Russia on taxation of foreign investors and commercial organizations with foreign investments - Member
- Association of European Businesses - Member
- International Fiscal Association - Member
- Russian Union of Industrialists and Entrepreneurs (RSPP) - Member
- Russian Chamber of Commerce - Member
- Russia (2007)
- MGIMO, Russia (2011)
- MGIMO, Russia (2007)
- 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
- Co-author, "New Incentives for Major Investments," Baker McKenzie InsightPlus, April 2020
- Co-author, "Additional Tax Support Measures During COVID-19 Pandemic," Baker McKenzie InsightPlus, April 2020
Baker & McKenzie - CIS, Limited is a member of Baker & McKenzie International, a Swiss Verein.