With the development of digital services of the Federal Tax Service of Russia, desk tax audits (CFS) are becoming increasingly important in detecting violations. 

Accounts receivable during the transition from USN to OSN as income from the implementation of IT business

This dispute confirms that the "business fragmentation" schemes based on the mass registration of separate sole proprietors under a single brand no longer work.

For the first time, based on the results of the VNP, claims regarding "business fragmentation" resulted in additional charges not on corporate income tax or VAT, but on mineral extraction tax.

The IT company was able to prove in court the legality of attributing accounts receivable to sales income during the transition from USN to OSN.