Dmitry Zapol

Lawyer
United Kingdom, London
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Experience: 11 years
Specialisation
Alternative Dispute Resolution
Corporate Law
Intellectual Property
International Law
Real Estate
Tax
Professional summary

I am a Russian-speaking international tax advisor at a London-based private consultancy with practical knowledge of the principles of individual and corporate international taxation and cross-border business planning. I have an excellent understanding of UK and Russian tax systems, particularly in dealing with international transactions and individual tax planning, particularly connected with immigration. I have a good understanding of the major European tax systems — Austria, Cyprus, Luxembourg, Malta, Netherlands, Switzerland. I am also a specialist in Russian corporate and commercial domestic legislation.


My clients are multinational SMEs, international entrepreneurs and HNWIs. I advise on cross-border tax-efficient business and investment structures and restructuring including commercial and residential real estate transactions. I deliver international tax solutions for cross-border intellectual property rights allocation and transfer pricing. I have significant practical experience addressing international residence and beneficial ownership issues. Many of my individual clients are high-net-worth Tier 1 Investors and Entrepreneurs coming to the UK.


I have spoken at numerous international conferences and taught international tax planning at the Law Faculty of Saint-Petersburg State University (SPbGU) and Moscow State Academy of Law named after Kutafin (MGYuA). I am a guest lecturer at MA in Taxation at the Institute of Advanced Legal Studies, University of London.


I have an excellent network of professional contacts across the US, Europe and the CIS. I speak English and Russian and I am fluent in French.


I am qualified to practice law in Russia.


Experience
International Tax Advisor
International Fiscal Services (IFS)
2010 - Present
I provide comprehensive international tax planning advice to a wide array of clients, and my recent experience includes:

• advising a major shipping company on cross-border corporate restructuring with a view to optimise dividends and royalties taxation through changing holding company's jurisdiction and establishing an IPR-owning SPV;
• advising London’s National Theatre on staging a play on Broadway, including advising on the choice of a legal entity, tax-efficient cross-border financing and remitting profits to the UK. Presently engaged in advising the same client on staging the play in Toronto;
• advising an international trading group on tax-efficient goods sourcing in China and establishing business presence in Bangladesh;
• advising an Australian listed mining company on acquisition of a foreign production subsidiary, including advising on the appropriate holding structure, tax-efficient financing and remuneration of the key employees;
• developing a tax-efficient operational strategy for a medium-sized international conferences organiser, seeking to establish its presence in Russia, East Asia and Australia, with a particular focus on cross-border IPR licensing and transfer pricing implications;
• advising a UK resident HNWI on Russian personal taxation and application of the Russia-UK double tax treaty;
• developing a tax-efficient operational strategy for a group of international entrepreneurs and investment funds, seeking to conduct real estate investment activity in Russia;
• advising an HNWI on his residence issues and personal tax liability with a particular focus on rebutting a taxation and residence claim of a major EU jurisdiction.
Associate
Moscow Bar Association "Barschevsky and Partners"
2004 - 2010
Part of a five-member team working alongside the firm’s partner as well as advising my own Russian and foreign clients, including UK and US law firms, companies and individuals in areas such as:
• domestic and cross-border tax planning, including advice on PEs and DTTs issues;
• disposing of and acquiring assets via turn-key cross-border companies sale and purchase;
• establishing internal corporate governance procedures following Russian and foreign clients’ specifications;
• due diligence of Russian companies at the request of their Russian and foreign counterparties;
• advising foreign law firms on Russian corporate and commercial law.

Personally involved in the following:
• advising a shareholder of one of the world's five largest independent energy traders on his rights and risks under the SHA governed by English law (leading counsel);
• advising a Russian Internet entrepreneur on attracting US$2,500,000 venture financing from a US investment fund (leading counsel);
• advising a Moscow-based Turkish company on attracting land-secured finance from a UK lender under a US$50,000,000 joint-venture agreement (interests of the counterparty represented by Linklaters);
• advising a Czech investment fund on acquiring property in Russia under a US$27,000,000 SPV share-purchase agreement (interests of the counterparty represented by White & Case);
• advising a Dubai holding company on setting up and managing Russian/Cyprus land-owning subsidiaries worth in excess of US$100,000,000;
• advising a Swiss clothes manufacturer on establishing and running its Russian branch (leading counsel);
• advising a Russian high net-worth individual relocating its Russian assets to Canada through Cyprus holding companies and off-shore trusts (leading counsel and team leader).

Publications: regular contributor to Russian financial and legal press under my own name; member of a panel of experts at Consultant – Russian leading corporate finance magazine (www.c2f.ru)
Education
Chartered Institute of Taxation (CIOT)
Advanced Diploma in International Taxation (ADIT), affiliate
2010 - 2012
https://www.tax.org.uk/adit-international-tax
King's College London, U. of London
Master's Degree, LL.M Tax Law, Pass with Merit
2009 - 2010
Modules taken:
• Taxation of Business Enterprises (sole traders, partnerships and companies; corporate reconstructions)
• Tax & Estate Planning (IHT, CGT and IT planning for trusts and individuals; foreign element)
• International Tax Law (application and interpretation of DTTs)
• Value Added Tax
• Research essay on whether the UK is a tax haven for non-domiciled non-resident individuals
• International Tax Law 3 @ Institute of Advanced Legal Studies (International Tax Planning) (optional course)
University of Durham
LL.B. (European Legal Studies), Law United Kingdom, Durham, 1999 - 2003
1999 - 2003
Third year spent abroad as an ERASMUS student at Université de Rouen, France – the first non-EU citizen at University to be awarded such opportunity
Moscow State Academy of Law named after O.E. Kutafin (MSAL)
Bachelor’s Degree, Law
1999 - 2001
Part-time course to allow me to practice Russian law following my return from the UK.
Services
Tax
Corporate Tax
Honors, Awards, Publications
IBSA/IFS/Memery Crystal LLP
April 28, 2015
Dmitry Zapol & Naomi Lawton provide a 45 minute webinar on resident non-domiciles & overseas investors to the UK. In his presentation Dmitry and Naomi will address the following practical matters:

-Becoming UK resident at the appropriate time and avoiding common mistakes.
-Creating clean capital and investing it without unexpected UK tax liability.
-Tax-efficient investments in UK property
IFS
March 1, 2015
The article -- part of IFS's monthly newsletter -- explains the role clean capital plays in UK individual tax planning.
From Rus
IFS
April 1, 2014
The letter -- part of IFS's monthly newsletter -- considers unique tax planning issues encountered by international sportsmen and entertainers.
Languages
English
Native or bilingual proficiency
Russian
Native or bilingual proficiency
French
Professional working proficiency