metrica
Yulia Pavlova
Yulia Pavlova Yulia Pavlova

Yulia Pavlova

  • Industries

    Construction, FMCG, Manufacturing companies

  • Qualifications

    Chief Tax Consultant

  • Industries

    Construction, FMCG, Manufacturing companies

  • Qualifications

    Chief Tax Consultant

Specializes in legal support of clients' activities on contentious taxation issues, assessment and mitigation of tax risks, tax structuring. She is involved in projects to represent clients in tax disputes at the pre-trial stage. She worked for a prominent international audit company and tax authorities.

Cases

38 mln ₽
Support of tax audits

38 million ₽ Representing a construction company in a field tax audit

The initial additional charges were based on the suggestions that the taxpayer used the optimization scheme with the help of "dishonest" contractors.

  • Industry

    Construction

  • Process description

    In the course of the audit, it was established that all disputed contractors were involved and their officials were interrogated, who actually confirmed their participation in these companies and the scope of work undertaken. In addition, the audit was followed by the recovery of partially lost primary documentation that confirmed the partial performance of the work by the disputed contractors.

  • Result

    As a result of the audit, tax claims amounted to 10 million ₽. Thus, as a result of successful work on support of the audit it was possible to avoid large additional payments in respect of "dishonest" contractors.

  • Employees involved

    Alexander Dmitriev, Yulia Pavlova

Successfully
Advice on taxation of CFCs

Support of the client at the stage of advising on payment of taxes from CFC profits, as well as assistance in preparing a tax amnesty declaration

Services were rendered to the beneficiary of a construction company for retrospective disclosure of information on participation in a controlled foreign company and on the existence of bank accounts opened outside the Russian Federation.

  • Industry

    Construction

  • Process description

    At the time of drawing up and submission of notifications to the tax authorities the statute of limitations under p. 1 of Article 129.6 of the Tax Code had not expired, i.e. the client still had the risk of tax liability for untimely disclosure of information about the CFC. In order to exclude tax liability for failure to submit CFC notifications for previous tax periods, the client was provided with services to prepare a special tax declaration allowing to apply the tax amnesty under the Federal Law of May 29, 2019 № 110-FZ within the voluntary declaration of their assets. Also within the framework of the project we assessed the grounds for the absence of an individual's obligations to withhold personal income tax from the profit of a CFC.

  • Result

    As a result of legal defense, tax liability and penalties for late submission of CFC notifications due to the application of tax amnesty provisions were avoided

  • Employees involved

    Yulia Pavlova, Anastasia Garipova

139 mln ₽
Pre-court settlement of tax disputes

The reality of subcontractors' activities was proved and the claims of the tax authority were withdrawn.

Claims of the tax authority to have "unscrupulous contractors" in the chain of subcontractors were disputed.

  • Industry

    Construction

  • Process description

    With the help of additional tax control measures, the reality of subcontractors' activities was proved. The absence of intent in the client's actions was proved. The tax authority calculated tax liabilities without primary documents.

  • Result

    Claims of the tax authority on the field inspection report were appealed and withdrawn. A positive pre-trial appeal against the acts of the tax authorities in favor of the taxpayers under 54.1 of the Tax Code was formed.

  • Employees involved

    Olga Savina, Anastasia Garipova, Alexander Dmitriev, Yulia Pavlova

Successfully
Tax monitoring

Preparation of documents for joining the tax monitoring system, updating accounting policy for tax accounting purposes

Accompanying the transition of a major trading company to tax monitoring

  • Industry

    FMCG

  • Process description

    Within support of the procedure of transfer to tax monitoring the client was rendered services on preparation of documents according to the requirements of the Federal Tax Service Russian FTS. In particular, it was actualized and brought in compliance with the effective tax legislation, the accounting policy for tax accounting purposes, documents regulating the company's internal control system were prepared of the company, and prepared tables and data on coordinators of of subdivisions and levels of control within the company.

  • Result

    Successful work on the analysis and preparation of documents required for the transition to tax monitoring, as well as interaction with the tax authority to address procedural issues in connecting to the tax monitoring system, allowed the client to take advantage of the transition to this mode of tax control and reduce the risk of additional additional tax assessments.

  • Employees involved

    Mikhail Begunov, Yulia Pavlova

Successfully
Tax structuring

Transaction structuring and tax planning at FMCG group of companies

Initially, the client set the task of structuring transactions between interdependent persons within a group of companies

  • Industry

    FMCG

  • Process description

    In the course of structuring the transactions, risks in terms of price thresholds between interdependent companies within the group were established, regulations and additional rules were developed and implemented by all companies of the group to justify the correct application of prices when selling products within the group, as well as to support the feasibility of transactions between them.

  • Result

    As a result, successful structuring and tax planning efforts eliminated risks in excess of 80 million ₽.

  • Employees involved

    Yulia Pavlova, Anastasia Garipova

70 mln ₽
Support of tax audits

Support of a field audit of a construction company and preparation of a tax reconstruction calculation that allowed to reduce the amount of tax claims by half

During the on-site tax audit, the Inspectorate found that the Company had concluded contracts for construction work and the supply of building materials with "technical" organizations that were financially and administratively controlled by the Company.

  • Industry

    Construction

  • Process description

    The task was complicated by the fact that - the volume of money transfers from the Company to "technical" organizations was 70% and higher; - Access to bank accounts and the electronic document management system with the fiscal authorities was carried out from the same device at the same time interval; - overlap of key employees; - coordination of business activities of "technical" organizations was performed by the Company; - the Company had direct relations with the actual suppliers and contractors before the inclusion of "technical" organizations in the chain of suppliers and contractors; - part of funds sent by the Company to the accounts of "technical" organizations was subsequently transferred by them to the accounts of actual suppliers and contractors.

  • Result

    Our lawyers have achieved the application of tax reconstruction according to the letter № БВ-4-7/3060@ of 10.03.2021 issued by the Federal Tax Service of Russia, thanks to which the Inspectorate has taken into account the real amount of expenses, attributable to the services of actual contractors and suppliers. Also, to confirm the reality of the expenses we have prepared and submitted a package of documents. Actions of Tax Compliance lawyers helped to reduce the amount of tax claims by half and formed the practice of tax reconstruction.

  • Employees involved

    Mikhail Begunov, Yulia Pavlova, Anastasia Garipova

Successfully
Criminal defense of business for tax crimes

Represented a major supplier of shut-off and control valves in a criminal case brought under Article 199 of the Russian Criminal Code before the tax authorities' decision on the field audit.

Reduced the amount of damage by six times and achieved the termination of the criminal case

  • Industry

    Manufacturing companies

  • Process description

    At the stage of pre-trial appeal of the tax authorities' decision, the law enforcement officers included in the audit, without waiting for the completion of the tax audit, forwarded the collected materials to the investigating authorities for initiation of a criminal case under part 2 article 199 of the Criminal Code. The criminal case was brought against the CEO and an unidentified group of people from the company's management. The amount of damage, according to the tax and investigative authorities amounted to more than 500 million rubles.

  • Result

    In accordance with the correctly built strategy of defense in the investigation of the criminal case and as a result of additional measures of tax control, lawyers and employees of Tac Compliance provided documents on "tax reconstruction", disclosed the real tax liabilities, as well as conducted an examination of the costs of transporting goods, which allowed to reduce the damages to 80 million rubles and termination of the criminal case on the fact of absence of corpus delicti in connection with the payment of arrears.

  • Employees involved

    Mikhail Begunov, Alexander Dmitriev, Yulia Pavlova

Publications