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 Baker McKenzie in 2007, Kirill 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.
Representative Legal Matters
- Advised on tax structuring and various tax issues in M&A deals in oil & gas and other industries, including tax structuring for Weatherford International in the (approximate) USD 450 million acquisition of TNK-BP International’s Oilfield Services Division.
- 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 (ie, controlled foreign companies rules, beneficial ownership and corporate tax residency based on effective management and control tests) and court practice on thin-capitalisation.
- Advised Russian high net worth individuals on setting up various wealth management and estate planning structures, including structures using foreign trusts and foundations.
- Acted as tax counsel on multiple domestic and cross-border securitisations, including the following recent securitisations of mortgage loan portfolios: RUB 13 billion securitisation for AKB Absolut Bank, RUB 3.3 billion securitisation for AKB Investtradebank, RUB 3 billion securitisation for Asian Pacific Bank.
- Advised on various financial transactions, including acting as tax counsel in connection with the Eurobond issuance of KOKS Group, advising Litnium Investments on tax issues in connection with a secured loan for USD 21 million from Eurohypo AG.
- Advised on tax compliance and developing tax strategies for multinational companies in connection with transfer pricing, tax-efficient refinancing of local operating entities in view of the Russian thin capitalization rules and judicial doctrines of business purpose and economic substance, including advising the American TV and film production and distribution unit of a Japanese technology and media conglomerate on its Russian operations, advising a US-based multinational computer technology company on various Russian tax issues.
Professional Associations and Memberships
- American Chamber of Commerce (AmCham) - Tax Committee, Co-chair
- 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)
Author, "The Chimera of the Beneficial Ownership Rule in Russia," Bloomberg BNA, 2017
Author, "Automatic Information Exchange with Russia: Conditions and Implications," 28 Journal of International Taxation 58, 2017
Author, "Certain Russian Tax Issues of Securitisation Transactions," Encyclopedia of Russian Securitisation, 2014
Speaker, "Deoffshorization – taxation aspects," Business Meeting of AEB Taxation Committee with Sergei Shatalov, Deputy Minister of Finance, October 2014
Speaker, "Beneficial Ownership Concept: the OECD approach and Russian Draft Law approach," AmCham Tax Committee Meeting, September 2014