Natural resources and energy
Industries
Natural resources and energy
- supporting the process of excluding production and other facilities of energy companies from the list of immovable property in respect of which the tax base is determined as their cadastral value;
- support of disputes with the tax authorities related to the qualification of the property of energy companies as movable / immovable;
- analysis of tax risks associated with qualification of the facilities of energy companies as immovable property;
- analysis of the risks of applying tax exemptions in relation to the facilities of energy companies and the development of recommendations to minimize them;
- assessment of tax risks associated with accounting losses from debt restructuring and development of recommendations for their minimization;
- assessment of electric grid companies' tax reserves related to non-contractual electricity consumption.
Industry Experts
Some our cases
Support of the client in the field tax audit and pre-trial appeal on the validity of the application of the reduced tax rate at source
Supporting a dispute over retrospective application of the results of cadastral value revision in the interests of a major generating company
Defending the interests of a major generating company in a dispute over the treatment of "golden parachutes" as expenses for corporate income tax purposes.
Tax support for the creation and operation of a large investment partnership
Representing a major oil producer in court to reclaim an invoice
Supporting a dispute over the exclusion of production buildings of one of Russia's largest generating companies from the list of immovable property for which the tax base is determined as the cadastral value
Legal support of an acquisition of assets in India
Defending a major energy company in court on the issue of qualification of property as movable/immovable property
Analysis of the procedure of debt financing within the group of companies with minimization of tax risks
Appealing the results of an on-site tax audit in respect of a company engaged in the extraction of minerals
A Russian oil and gas company appealed against a tax authority's demand for payment of tax debts
Review of the case of ROSATOM GLASS FIBER JSC
The BM Bank JSC case: the tax authority successfully challenged the receipt of tax benefits under the ZPIFRecently, there has been an increase in the popularity of using a PIF as a tool for investing capital and structuring asset ownership. One of the reasons for this trend is the inherent tax efficiency of investment funds.
Computer Systems and Networks has appealed in court the decision of the tax authority to charge over 76. 5 million rubles in tax arrears.
The Supreme Court of the Russian Federation has confirmed the right of tax authorities to request documents during a desk checkWith the development of digital services of the Federal Tax Service of Russia, desk tax audits (CFS) are becoming increasingly important in detecting violations.
Accounts receivable during the transition from USN to OSN as income from the implementation of IT business
Proceedings on additional arrears of over 1 billion rubles in respect of a large fur trading networkThis dispute confirms that the "business fragmentation" schemes based on the mass registration of separate sole proprietors under a single brand no longer work.
Method of calculating mineral extraction tax when reducing additional charges within on-site tax auditFor the first time, based on the results of the VNP, claims regarding "business fragmentation" resulted in additional charges not on corporate income tax or VAT, but on mineral extraction tax.
Accounts receivable during the transition from USN to OSN as income from the implementation of IT businessThe IT company was able to prove in court the legality of attributing accounts receivable to sales income during the transition from USN to OSN.
The SC on the statute of limitations for refunding overpaid tax: analysis of ruling No. 5-KAD25-24-K2The ruling of the SC of the Russian Federation sets the direction for law enforcement practice in similar disputes concerning the refund of overpaid personal property tax.
It's impossible to reduce personal income tax charges by paid professional tax without involving individualsThe Supreme Council of the Russian Federation draws attention to approaches to the calculation of arrears when reclassifying personal income tax as personal income tax.
The SC of the RF has consolidated a number of approaches to the consideration of disputes on the restoration of corporate controlThe issues of corporate control in the case of a beneficiary in custody and the termination of a company's legal capacity in a foreign jurisdiction are addressed.
Income from P2P transactions with cryptocurrency is recognised as an integral part of entrepreneurial activity of a sole proprietorshipThe court considered the lawfulness of not including P2P transactions involving the purchase and sale of cryptocurrency in the tax base of an individual entrepreneur on the simplified taxation system who declared a different OKVED
The granting of instalments may be terminated if payment thereunder was made without taking into account the order under the Unified Tax CodeTC experts considered the issue of granting instalment payments on the example of a court decision of the Rostov Region Court of Arbitration.
In anticipation of the legal position of the SCEC of the Supreme Court of the Russian Federation, Tax Compliance experts presented the background of the case.
