Ivan Tsvetkov
Ivan Tsvetkov Ivan Tsvetkov

Ivan Tsvetkov

Chief Tax Consultant
Industries

Manufacturing, IT-business, Retail, Real estate and construction, Transport and logistics

V CARD V CARD
Biography

Ivan's experience in taxation is more than 8 years, including both work for the tax authorities in the field of field tax audits, as well as control and analytical work, and at rated Russian law firms.

He specializes in supporting field tax audits, appealing tax claims, identifying tax risks, developing and implementing tax compliance systems, and advising on complex issues of Russian taxation.

Ivan advises the leading Russian banks and companies in various industries on identification and mitigation of tax risks, as well as on pre-trial appeal of tax claims against the largest construction and production companies.

Certified tax consultant. Member of the Chamber of Tax Advisers. Regular speaker of specialized tax webinars, author of articles and comments for the media. Tax lecturer at a leading online financial university.

Cases

Production Successfully
Support in the framework of pre-test analysis

Assisting the client in preparing a legal position on the "splitting" of the business

  • Employees involved

    Mikhail Begunov, Nikita Zharov, Ivan Tsvetkov

  • Process description

    The tax authority, as part of its pre-inspection analysis, concluded that the taxpayer used a "split" business scheme. In particular, the tax authority believed that: (1) the inclusion of a retailer who applied the simplified taxation system ("Counterparty") in the chain "producer - end buyer" is due solely to tax motives; (2) the taxpayer and the counterparty are interdependent business entities. In view of the above, the taxpayer was requested to adjust its tax liabilities and submit revised tax returns. The Tax Compliance team helped the client to elaborate a legal position confirming that (1) business transactions with the Counterparty are real; (2) business transactions with the Counterparty have a business purpose; (3) no interdependence exists between the taxpayer and the Counterparty.

  • Result

    The tax authority accepted the arguments of the taxpayer.

Construction 50 million ₽
Pre-court settlement of tax disputes

Development of a legal position confirming the reality of relations between a leading Russian construction company and its counterparties, as well as the unlawful additional accrual of income tax

  • Employee involved

    Ivan Tsvetkov

  • Process description

    The company purchased goods used in construction at the customer's facilities, paying for the supplies by means of the transfer of promissory notes. As a result of an on-site tax audit, the tax authority concluded that the Company's expenses for purchasing the aforementioned goods were not actually confirmed, on the basis of which it assessed additional VAT and corporate profit tax on all transactions with counterparties. The tax authority also assessed additional personal income tax and insurance contributions on the amount of promissory notes transferred as payment for the above transactions, qualifying these expenses as dividends of a person controlling the Company.

  • Result

    As a result of developing a legal position, preparing objections to the act, supporting additional tax control measures, preparing objections to the supplement to the act, as well as representing the Company during the consideration of audit materials by the tax authorities, the tax authorities managed to prove the unreasonableness of additional charges in terms of income tax, personal income tax and insurance premiums, thereby reducing the amount of additional charges by 76%.

Construction 410 mln ₽
Pre-court settlement of tax disputes

Defended a Russian company specializing in wholesale trade of equipment for mining and construction against tax claims under sec. 54.1 of the Russian Tax Code at the stage of objections to an addendum to a tax audit report.

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.

transport Successfully
Advising on the application of tax legislation

Advising the client on personal income taxation of individuals working outside the Russian Federation

  • Employees involved

    Mikhail Begunov, Ivan Tsvetkov, Nikita Zharov

  • Process description

    The Tax Compliance team was given the task of analyzing the tax risks associated with the procedure for taxing the income of individuals working outside of Russia.

  • Result

    The Tax Compliance team has identified the areas most exposed to tax risks and prepared recommendations for improving document management (in terms of processing the client's labor relations with employees working outside of Russia) based on the results of the analysis.

All case studies

Publications