The tax authority found damage to the budget as a result of the application of non-market prices in cross-border transactions with the interdependent Dutch company VWS. 

Being in a preferential region without actually carrying out business activities there does not save you from additional charges.

In early February, in the case of IP Danilyuk, the courts considered the issue of the existence of a scheme of "business fragmentation".

Review of the case of ROSATOM GLASS FIBER JSC

Recently, there has been an increase in the popularity of using a PIF as a tool for investing capital and structuring asset ownership. One of the reasons for this trend is the inherent tax efficiency of investment funds.