Alexey has been working in the field of tax consulting for more than 6 years. Prior to joining Tax Compliance, he worked in rated Russian law firms.
He takes an active part in pre-trial and judicial settlement of tax disputes, projects on structuring activities in various industries, as well as preparing consultations on complex tax issues.
He has experience in providing consulting services and supporting on-site tax audits in such areas as: the sphere of international taxation, in particular, issues of FPA and passive income; challenging decisions of the tax authority in cases of "fragmentation"; challenging VAT amounts associated with the movement of goods across the customs border (HS).
Preparation of a legal position confirming the reality of freight forwarding services in conjunction with the reconstruction of a number of episodes
Confirm the actual provision of transport and freight forwarding services rendered to the client, to apply the reconstruction of transportation services, to confirm the absence of a scheme to obtain an unjustified tax benefit
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.
Preparation of a legal position confirming the reality of engaging subcontractors
Confirm the actual performance of works by subcontractors for the construction of the Moscow-St. Petersburg Expressway, confirming the absence of a scheme to obtain an unjustified tax benefit
An on-site audit was carried out in respect of the client, as a result of which additional VAT was charged on the counterparty. According to the tax authority, in fact the specified work was not performed by the disputed counterparty, but was performed by the taxpayer itself or other organizations. In the legal defense developed a legal position, which proved that the performers were part of the same group of companies, consisting of more than 12 legal entities. The taxpayer, when working with the counterparty considered it as a single economic entity and could not know about the corporate structure of the counterparty.
According to the results of the developed legal position it was possible to confirm the economic feasibility of the transaction, as well as the reality of the financial and economic activities of the disputed counterparties.