Pre-court settlement of tax disputes

  • 343 mln ₽

    Withdrawn claims of the tax authority against suppliers of raw materials for medicines

    Pre-court settlement of tax disputes

    We disputed the claim of the tax authority to suppliers of raw materials for medicines.

    • Industry

      Pharmaceuticals

    • Process description

      At the stage of objections and additional activities it was proved that it is necessary to measure quantitative indicators at the beginning and at the end of the production process. The tax authority has been provided with calculations on writing-off materials purchased from contested counterparties and information on raw material remainders.

    • Result

      Claims of the tax authority for income tax were partially withdrawn. The taxpayer's objections were partially satisfied in the amount of 343 million ₽. Positive practice of pre-trial appeal against acts of tax authorities in relation to manufacturers of medicines was formed taking into consideration the specifics of the industry.

    • Employees involved

      Mikhail Begunov, Anastasia Garipova

  • 39 mln ₽

    It was proved that there was no affiliation with the purchaser company, claims of the tax authority were withdrawn

    Pre-court settlement of tax disputes

    Claims of the tax authority on redistribution of the company's income through the affiliated purchasers were eliminated.

    • Industry

      FMCG

    • Process description

      Additional tax control measures were taken. Employees and officials of the purchaser company were interrogated. Lack of client's company affiliation was proved. The act of field tax audit was appealed.

    • Result

      The taxpayer's objections are satisfied. The decision on additional accrual of 5 million ₽ was formed. Positive practice of pre-trial appeal against acts of tax authorities in terms of disputes on "business split” in favor of taxpayers under 54.1 of the Tax Code was formed.

    • Employee involved

      Olga Savina

  • Successfully

    The decision of the field tax audit was reversed in the pre-trial procedure

    Pre-court settlement of tax disputes

    The field tax audit period was disputed.

    • Industry

      Information technology

    • Process description

      The tax authority appointed a field audit after the company's reorganization started, although the field audit partially covers the periods of previous audits. An appeal was lodged to a higher tax authority. The field tax audit was reversed.

    • Result

      We cancelled the results of the field tax audit for the previously inspected period. There is a positive practice of pre-trial appeal against the decision of tax authorities to appoint an on-site tax audit for the same tax period in case of its appointment in connection with the reorganization or liquidation of the company under Article 89 of the Tax Code.

    • Employees involved

      Mikhail Begunov, Anastasia Garipova

  • 50 mln ₽

    It was proved that there was no affiliation with suppliers, and reality of subcontractors’ activities.

    Pre-court settlement of tax disputes

    Claims of the tax authority were partially eliminated. Claims of the tax authority on the involvement of "unscrupulous counterparties" were withdrawn.

    • Industry

      FMCG

    • Process description

      With the help of additional tax control measures, the reality of subcontractors' activities was proved. The absence of intent in the actions of the client and lack of affiliation with suppliers, which partially confirmed the disputed shipments, was proved.

    • Result

      Claims of the tax authority for the field inspection report were appealed and partially withdrawn. Positive pre-trial appeal against the acts of tax authorities in favor of taxpayers under 54.1 of the Tax Code was formed.

    • Employees involved

      Mikhail Begunov, Alexander Dmitriev, Olga Savina

  • 139 mln ₽

    The reality of subcontractors' activities was proved and the claims of the tax authority were withdrawn.

    Pre-court settlement of tax disputes

    Claims of the tax authority to have "unscrupulous contractors" in the chain of subcontractors were disputed.

    • Industry

      Construction

    • Process description

      With the help of additional tax control measures, the reality of subcontractors' activities was proved. The absence of intent in the client's actions was proved. The tax authority calculated tax liabilities without primary documents.

    • Result

      Claims of the tax authority on the field inspection report were appealed and withdrawn. A positive pre-trial appeal against the acts of the tax authorities in favor of the taxpayers under 54.1 of the Tax Code was formed.

    • Employees involved

      Anastasia Garipova, Alexander Dmitriev, Olga Savina, Yulia Pavlova

  • 193 mln ₽

    Claim of the tax authority on improper use of VAT credits was disputed.

    Pre-court settlement of tax disputes

    To dispute the claims of the tax authority on the improper use of tax credits for VAT.

    • Industry

      Information technology

    • Process description

      Additional tax control measures were taken. Evidence of the absence of interdependence with suppliers of equipment was presented. The price of the purchased equipment is indicated to be corresponding to the market level. All established violations concerned beneficiaries-importers of the supplied products, rather than the taxpayer.

    • Result

      Claims of the tax authority were disputed. A positive practice was formed on additional payments to companies that supply imported equipment through a chain of suppliers

    • Employees involved

      Mikhail Begunov, Anastasia Garipova, Alexander Dmitriev

Pre-court settlement of tax disputes