Optimization of tax risks associated with aircraft charter operations for one of the largest companies in Russia
transport
The client requested to analyze the current structure of interaction within the framework of aircraft charter contracts. The consultant was assigned the task to analyze tax risks and identify ways to minimize them. (The project was implemented by the employee before joining Tax Compliance)
As a result of the work done by the consultant was able to change the contractual structure, which allowed to minimize the risks of the client associated with the application of 0% VAT rate and others.
Denis Kozhevnikov
Preparation of a legal position confirming the reality of freight forwarding services in conjunction with the reconstruction of a number of episodes
transport
An on-site inspection was carried out in respect of the client, as a result of which additional VAT and income tax were charged on relations with controlled transit counterparties. According to the tax authority, the purchase of goods was actually carried out directly from organizations that apply special tax regimes (without VAT). As part of the legal defense developed a legal position to challenge the technical nature of the activities of the disputed counterparties, for part of the episodes was applied to the reconstruction of the income tax.
According to the results of the developed legal position it was possible to prove the lack of controllability between the participants in the chain of contractual relations, to confirm the economic feasibility of the transaction, as well as the reality of the financial and economic activities of the disputed counterparties.
Alexey Stanchin
transport
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
Mikhail Begunov
Analysis of tax risks in debt restructuring
transport
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.
Mikhail Begunov
Challenged the position of the tax authority on the audit of transfer pricing
transport
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.
Mikhail Begunov
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