Alexander Dmitriev

Alexander Dmitriev

  • Industries

    Construction, FMCG, Information technology

  • Qualifications

    Lawyer, Tax Consultant

  • Industries

    Construction, FMCG, Information technology

  • Qualifications

    Lawyer, Tax Consultant

Specializes in the analysis of organizations' activities regarding tax risks, support of clients in the course of tax audits, protection of business entities in tax disputes. Alexander's mediation and lawyer's investigations helped clients to complete their disputes at the pre-trial stage.

Cases

38 mln ₽

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

Support of tax audits

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

50 mln ₽

It was proved that there was no affiliation with suppliers, and reality of subcontractors’ activities.

Pre-court settlement of tax disputes

Claims of the tax authority were partially eliminated. Claims of the tax authority on the involvement of "unscrupulous counterparties" were withdrawn.

  • Industry

    FMCG

  • Process description

    With the help of additional tax control measures, the reality of subcontractors' activities was proved. The absence of intent in the actions of the client and lack of affiliation with suppliers, which partially confirmed the disputed shipments, was proved.

  • Result

    Claims of the tax authority for the field inspection report were appealed and partially withdrawn.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

  • Employees involved

    Mikhail Begunov, Alexander Dmitriev, Olga Savina

193 mln ₽

Claim of the tax authority on improper use of VAT credits was disputed.

Pre-court settlement of tax disputes

To dispute the claims of the tax authority on the improper use of tax credits for VAT.

  • Industry

    Information technology

  • Process description

    Additional tax control measures were taken. Evidence of the absence of interdependence with suppliers of equipment was presented. The price of the purchased equipment is indicated to be corresponding to the market level. All established violations concerned beneficiaries-importers of the supplied products, rather than the taxpayer.

  • Result

    Claims of the tax authority were disputed. A positive practice was formed on additional payments to companies that supply imported equipment through a chain of suppliers

  • Employees involved

    Mikhail Begunov, Anastasia Garipova, Alexander Dmitriev

139 mln ₽

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

Pre-court settlement of tax disputes

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

    Anastasia Garipova, Alexander Dmitriev, Olga Savina, Yulia Pavlova

Successfully

Successful tax audit to identify "problematic" counterparties

Tax Audit

The tax authority has sent an information letter to encourage the taxpayer to adjust the tax base for VAT and make an additional payment to the budget of 80 million ₽.

  • Industry

    Information technology

  • Process description

    In the course of tax audit of problematic counterparties, real tax risks in terms of relationships with suppliers were established, which amounted to 15 million ₽. In the other part of the requirements of the tax authority were not proved: the organization provided the primary documents with the substantiation of the reality of supplies, as well as the documents on full reflection by the suppliers of the amounts of proceeds from sales in VAT declarations, and their contact information.

  • Result

    As a result of a successful tax audit, the organization independently adjusted the tax base for VAT and paid 15 million ₽ on their own. This allowed avoiding field tax audits and additional penalties.

  • Employees involved

    Mikhail Begunov, Alexander Dmitriev

Publications

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