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.

The ruling of the SC of the Russian Federation sets the direction for law enforcement practice in similar disputes concerning the refund of overpaid personal property tax.

The Supreme Council of the Russian Federation draws attention to approaches to the calculation of arrears when reclassifying personal income tax as personal income tax.