Cases

• Employees involved

  Mikhail Begunov, Nikita Zharov

• Process description

  When selling products, the customer uses a customer loyalty bonus program. Under the said loyalty program customers accumulate bonuses, with which they can later pay up to 100% of the cost of purchased products. The client was interested in the analysis of tax risks and procedure of registration of cash receipts in case of full payment of the cost of production by purchasers with bonuses.

• Result

  As a result of the project realization Tax Compliance team managed to assess tax risks related to VAT and income tax for the Client and to suggest the ways of their minimization. In particular, in the course of the project Tax Compliance specialists: (1) analyzed the Client's loyalty bonus program; (2) developed proposals to minimize the risks associated with the recognition of such sales of goods for bonuses as a gratuitous one.

• Employees involved

  Alexey Stanchin, Alexander Dmitriev

• Process description

  A taxpayer turned to the Tax Compliance team as part of a consultation on minimizing tax risks. In particular, work was done on: (1) advising the client on the correctness of tax accounting (2) advising on the field tax audit; (3) interaction with the tax authority during the tax audit; (4) justification before the tax authority of the principles of accounting policy applied by the taxpayer. In connection with the above, the taxpayer was offered an action plan for interaction with the tax authority. The Tax Compliance team helped the client to develop a legal position confirming: (1) the reality of transactions; (2) the validity of the absence of additional income tax charges; (3) justify the need for additional VAT charges on tax "gaps".

• Result

  The tax authority accepted the taxpayer's arguments. The tax claim of 385 million ₽ was reduced to 46 million ₽ as a result of the project. Which is 12% of the original claim of the tax authority.

The reality of the activities of subcontracting organizations was proved and the claims of the tax authority were removed

• Duration

  February 2023 - May 2023

• Purpose

  Challenge the tax authority's claims that the company used "unfair counterparties" in a chain of subcontractors.

• Employees involved

  Mikhail Begunov, Ivan Tsvetkov

• Process description

  A tax authority refused to take into account VAT expenses and deductions in respect of a taxpayer's relations with several counterparties. Taks Compliance specialists have developed a position which provides for both a full appeal against additional tax assessments on several episodes and the application of "tax reconstruction".

• Result

  Arguments and arguments formed for the taxpayer were accepted by the tax authority. Tax claims were reduced by 80%: by more than 410 million rubles.

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

• Duration

  June 2019 - December 2019

• Employees involved

  Mikhail Begunov, Alexander Dmitriev

• 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, Nikita Zharov

• Process description

  Due to the imposed sanctions, "unfriendly" participants in a Russian company were planning to sell a business in Russia. The potential buyer of the business was a Russian retailer. The client was interested in analyzing tax risks, currency and anti-sanctions restrictions in relation to a potential transaction to acquire a business from unfriendly residents.

• Result

  The Tax Compliance team at the end of the project: (1) analyzed the application of anti-sanctions and currency regulation acts; (2) identified and described tax risks associated with the implementation of the transaction; (3) developed a plan for the implementation of the transaction taking into account all risks and restrictions.