Support of disputes with tax authorities

Mikhail Begunov, Nikita Zharov, Alexander Dmitriev

The tax authority conducted an on-site audit of the client for all taxes and levies for a three-year period. As a result of the on-site tax audit, the auditors made claims on transactions with a number of counterparties. In the tax authority's view, the client had recorded business transactions with 7 technical entities in breach of Article 54.1 of the Tax Code.

Tax Compliance specialists helped the client to successfully complete an on-site tax audit. In particular, in the course of the project the Team:

(1) helped develop a legal position as part of the preparation of objections to the act;
(2) represented the client in the meetings with the tax authorities;
(3) accompanied the client in the framework of additional tax control measures.

Due to the team's assistance, the testimony of the general director of one of the disputed counterparties was admitted into the tax audit file. The CEO's testimony helped convince the auditors that all of the client's business transactions with one of the disputed counterparties were real.

The tax authority's additional charge was reduced by 40%.