The Pravo.ru portal published an article based on the results of the conference "Tax Practice and Tax Disputes".
"Not always a change in the structure of a business is an unjustified tax benefit. The Federal Tax Service has established 17 signs that may indicate the receipt of such benefit due to splitting the business. However, lately the accent has been made on three main criteria. This is the absence of business purpose, commercial activity and independence. Absence of splitting is also pointed out by some attributes", - said Andrey Solomyanyi, partner of Tax Compliance law firm.
You can read the full article at the link.
The position of the Federal Tax Service on excise taxes on petroleum products in terms of mixing of different types of fuels20.09.2021