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Portrait of Hayk Safaryan

Hayk Safaryan

Head of Customs

Naberezhnaya Tower, block C
Naberezhnaya Tower Block C - 10 Presnenskaya Naberezhnaya
123112 Moscow
Languages English, French, Armenian

Hayk has been working in the firm and has been advising the clients on tax and customs matters since 2002.

Hayk’s practice encompasses all areas of domestic and international corporate tax planning. Hayk has an excellent track record in advising on the tax implications of M&A, JV, corporate restructuring and reorganisations, financing, real estate and securities transactions as well as in carrying out tax due diligence. 

Hayk also practises in the areas of currency regulation, customs and transportation law. He assists corporate clients on a variety of customs-related matters, including import and export controls, tariff classification, valuations, rules on determination of goods’ origin and customs audits. 

Hayk’s expertise in customs area makes him also for specialising in advising international group of companies on set-up wholesale and retail trade schemes in Russia, on the choice of schemes for imports to Russia and subsequent distribution of imported products.

Hayk assists clients regarding relations with the authorities during tax and customs audits. In addition to purely advisory work, he has been involved in tax and customs dispute resolution. In particular, he has extensive experience in challenging the results of tax and customs audits, in which he either ensured pre-trial settlement or successfully represented clients in Russian Courts of all levels.

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Memberships & Roles

  • CCI France Russie, Customs and Transport committee, Co-President
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  • 2010, Moscow State Academy of Law, Law faculty, Master in law
  • 2002, Moscow State University, Economics faculty, Master in international management
  • 2001, Aix-Marseille III University, Law faculty, Master in public economic law
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SEAM­LESS Leg­al re­cog­nised by Pravo-300 2022
We are more than happy to share our first re­cog­ni­tion as SEAM­LESS Leg­al by the na­tion­al rank­ing Pravo.ru-300. This year SEAM­LESS Leg­al has earned 17 re­cog­ni­tions, in­clud­ing Band 1 award for the In­sur­ance...
SEAM­LESS Leg­al ad­vises Nis­san on Rus­sia exit
SEAM­LESS Leg­al team has ad­vised ma­jor Ja­pan­ese car man­u­fac­turer Nis­san on its exit from Rus­sia.SEAM­LESS Leg­al team was led by firm’s man­aging part­ner Jean-François Mar­quaire, sup­por­ted by loc­al part­ners...
De­vel­op­ments in the reg­u­la­tion of di­git­al fin­an­cial as­sets and di­git­al...
Spe­cif­ic rules for the tax­a­tion of trans­ac­tions in­volving di­git­al fin­an­cial as­sets (“DFAs”) and “hy­brid” di­git­al rights, com­pris­ing DFAs and util­it­ari­an di­git­al rights (“UDRs”) have been in force since 14 Ju­ly 2022, when a law* amend­ing the Rus­si­an Tax Code (the “Law”) came in­to force.A leg­al frame­work for the cir­cu­la­tion of DFAs and UDRs was in­tro­duced in 2021, but did not touch upon tax as­pects. Pri­or to the in­tro­duc­tion of a spe­cial tax reg­u­la­tion, there was an act­ive dis­cus­sion re­gard­ing the treat­ment of DFAs and UDRs for tax pur­poses and the tax con­sequences of trans­ac­tions with them. It was clear that, without sup­ple­ment­ing the Tax Code with spe­cial norms, there would be many am­bi­gu­ities in the ap­plic­a­tion of the ex­ist­ing tax reg­u­la­tion to trans­ac­tions with DFAs and UDRs.As a res­ult of these dis­cus­sions, tak­ing in­to ac­count the spe­cif­ic nature of DFAs and UDRs as new ob­jects of civil rights, the Rus­si­an Tax Code has been fun­da­ment­ally im­proved. Some art­icles have been sup­ple­men­ted with spe­cial rules ap­plic­able to trans­ac­tions with these types of as­sets, and en­tirely new art­icles have ap­peared which fo­cus ex­clus­ively on DFAs and UDRs and the spe­cif­ics of cal­cu­lat­ing VAT, per­son­al in­come tax and cor­por­ate profits tax through­out the en­tire “life cycle” of such as­sets, as well as de­fin­ing the ob­lig­a­tions of tax agents.At the same time as the Law, amend­ments* to the Law on DFAs and oth­er laws were passed.Com­ment­sThe in­tro­duced reg­u­la­tion is quite sys­tem­at­ic and elab­or­ate, and the ad­op­ted amend­ments use the ter­min­o­logy es­tab­lished by the Law on DFAs, which should min­im­ise dis­crep­an­cies. In ad­di­tion, the spe­cif­ics of tax­a­tion of trans­ac­tions with DFAs and UDRs fit in­to the ex­ist­ing struc­ture of the Rus­si­an Tax Code, which en­sures trans­par­ency in their ap­plic­a­tion and makes it easi­er to elim­in­ate gaps in the tax reg­u­la­tion in the fu­ture.We will con­tin­ue to fol­low the emer­ging reg­u­la­tion of DFAs and UDRs and will keep you in­formed of the most sig­ni­fic­ant de­vel­op­ments and changes.* In Rus­si­an
Rus­sia ex­pands tax sup­port meas­ures in the IT sec­tor
Yet an­oth­er pack­age of meas­ures aimed at ex­pand­ing and cla­ri­fy­ing the cri­ter­ia for tax in­cent­ives for IT com­pan­ies was in­tro­duced mid-Ju­ly un­der Fed­er­al Law No. 321-FZ (the “Law”). Over­view of...
Tax­a­tion of e-ser­vices: back to ba­sics
1 Au­gust 2022
Po­ten­tial chal­lenges in pay­ing VAT on elec­tron­ic ser­vices
In the cur­rent eco­nom­ic and polit­ic­al en­vir­on­ment, and tak­ing in­to ac­count the lim­it­a­tions now im­posed by many for­eign banks with re­spect to the trans­fer of funds to Rus­sia, we ex­pect that for­eign pro­viders of elec­tron­ic ser­vices may face prac­tic­al dif­fi­culties with pay­ing VAT to the Rus­si­an budget for the first quarter of 2022. Ac­cord­ing to the ap­plic­able le­gis­la­tion, the tax is due to be paid on or be­fore 25 April 2022.Ac­cord­ing to the in­form­a­tion at our dis­pos­al, In­ter­re­gion­al tax in­spec­tion No. 7 in charge of the elec­tron­ic ser­vices’ agenda is col­lect­ing in­form­a­tion from tax­pay­ers on ex­pec­ted prob­lems with pay­ments with a view to provid­ing tech­nic­al solu­tions.That be­ing said, for­eign pro­viders of elec­tron­ic ser­vices in Rus­sia should con­firm with their for­eign banks in ad­vance wheth­er it is pos­sible to pay VAT to the Rus­si­an budget in due time. Any prob­lems iden­ti­fied may be re­por­ted to the In­ter­re­gion­al tax in­spec­tion No.7 via the feed­back form in the tax­pay­er’s on­line ac­count.For­eign pro­viders of elec­tron­ic ser­vices may also dis­cuss with their Rus­si­an cus­tom­ers the VAT pay­ment mech­an­ism for the flows. For ex­ample, the Rus­si­an cus­tom­er may choose to vol­un­tar­ily with­hold the VAT due from the pay­ment made to the for­eign pro­vider, us­ing the mech­an­ism provided in the let­ter* of the Fed­er­al Tax ser­vice dated 24.04.2019 No. СД-4-3/[email protected] However, this ap­proach may be ap­plied only in re­spect of fu­ture pay­ments to the for­eign pro­viders.* In Rus­si­an
Double tax­a­tion treat­ies
In this sec­tion of the Tax chapter of Do­ing busi­ness in Rus­sia, we out­line gen­er­al prin­ciples of double tax­a­tion treat­ies (“DTTs”) and give ex­amples of the tax rates ap­plic­able un­der sev­er­al DTTs to which Rus­sia is a sig­nat­ory.
Struc­tur­ing cross-bor­der con­tracts: Rus­si­an tax and cus­toms as­pects
We in­vite you to join a we­bin­ar on Struc­tur­ing cross-bor­der con­tracts: Rus­si­an tax and cus­toms as­pects, or­gan­ised by the Ja­pan­ese Desk at CMS Rus­sia.Join our ex­perts Georgy Daneliya, Hayk Sa­fary­an and...
In this sec­tion of the Tax chapter of Do­ing busi­ness in Rus­sia, we cov­er spe­cif­ic in­cent­ives avail­able to those in­vest­ing in the Rus­si­an eco­nomy.
Spe­cial tax re­gimes
In this sec­tion of the Tax chapter of Do­ing busi­ness in Rus­sia, we out­line three spe­cial tax re­gimes avail­able to cor­por­ate tax­pay­ers un­der cer­tain cir­cum­stances.
Tax­a­tion of in­di­vidu­als
In this sec­tion of the Tax chapter of Do­ing busi­ness in Rus­sia, we deal with in­come tax and in­di­vidu­al prop­erty tax.
Cor­por­ate tax­a­tion
In this sec­tion of the Tax chapter of Do­ing busi­ness in Rus­sia, we cov­er the cor­por­ate profits tax, VAT, ex­cise du­ties, the cor­por­ate prop­erty tax, payroll-re­lated levies, taxes on nat­ur­al re­sources, trans­port tax, the sales duty and state du­ties.