Preparation of a legal position to confirm the reality of the relationship with subcontractors
Tax control measures were carried out in relation to the client, the tax authority indicates the need to clarify the tax liabilities of the client on the subcontractor. According to the tax authority, the contractor involved could not perform work for the client. As part of the legal defense and preparation of a response to the protocol of the commission was able to prove the lack of involvement of the client in the regulation of the disputed counterparty, to confirm the economic feasibility of engaging a controversial counterparty.
The implementation of the project allowed to save the client's current assets, exclude the possibility of the appointment of a field tax audit.
Support for the procedure of obtaining installment payments on taxes
The client was provided with services for the preparation of documentary substantiation of compliance with all the criteria for obtaining installment payments, calculated financial indicators of solvency and current liquidity to obtain installment payments due to the threat of bankruptcy risks. An analysis of the most rational way to ensure tax liabilities, depending on the value of the company's assets and, in general, the procedure for obtaining one or another type of security. Prepared documents in respect of the property of the company, acting as security for the performance of obligations to pay taxes within the period specified in the schedule of debt repayment.
The tax authority accepted the documents and the application for installment payment, the client was given the opportunity to pay tax during the calendar year.
Advice on the legality of the calculation of excise duties as a result of improving the quality of an existing petroleum product
The client in the conditions of the oil depot, is engaged in improving the quality of fuel. Since the client did not produce a new product, no excise tax was calculated on the product received. In 2020 the Ministry of Finance of Russia changed its position, on which a number of clarifications were issued, on the basis of which the tax authority sent the client an information letter with the proposal to clarify its tax liabilities for the past tax periods. The client requested advice on the lawfulness of calculating excise duties on petroleum products due to a change in the approach to the interpretation of provisions of the Tax Code by the Russian Ministry of Finance.
The client developed a legal position to challenge the actions of the tax authority on the procedure for determining the object of taxation
A client engaged in helicopter transportation rendered consulting services for the analysis of tax risks in a transaction involving the sale of interest-bearing bonds, which resulted in a loss. Due to the fact that the securities are not traded on the organized securities market and were sold to a related party, there was a risk of additional profit tax charges when accounting for expenses on the purchase of securities.
Implementation of the project made it possible to eliminate the probability of tax claims
Analysis of tax risks in debt restructuring
A client of a major airline company was advised on analyzing tax risks associated with the purchase of discounted debt from credit institutions and the offsetting of debt obligations against securities.
Legal position aimed at justification and structuring of the transaction allowed the client to exclude the possibility of tax claims on income tax, as well as to take into account the losses of previous tax periods in the expenses.