Challenged the position of the tax authority on the audit of transfer pricing
Mikhail Begunov
Price adjustment would have entailed an additional charge of income tax on the formed tax base based on the market prices of the transaction. The project developed a legal position indicating that the formed pricing corresponds to the market level, because the calculation of the cost of the taxpayer's goods contains production costs, economically justified in terms of the type of activity.
As a result of the successful legal defense, additional tax assessments in the amount of 280 million ₽ were avoided.