Olga Savina

Olga Savina

  • Industries

    FMCG, Construction

  • Qualifications

    Chief Tax Consultant

  • Industries

    FMCG, Construction

  • Qualifications

    Chief Tax Consultant

Specialized in representing clients in arbitration courts. She has worked for over ten years in tax authorities and financial companies.

Cases

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 Claims of the tax authority on the involvement of "unscrupulous counterparties" were withdrawn.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    Claims of the tax authority for the field inspection report were appealed and partially withdrawn.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

39 mln ₽

It was proved that there was no affiliation with the purchaser company, claims of the tax authority were withdrawn

Pre-court settlement of tax disputes

Claims of the tax authority on redistribution of the company's income through the affiliated purchasers were eliminated.

  • Industry

    FMCG

  • Process description

    Additional tax control measures were taken. Employees and officials of the purchaser company were interrogated. Lack of client's company affiliation was proved. The act of field tax audit was appealed.

  • Result

    The taxpayer's objections are satisfied. The decision on additional accrual of 5 million ₽ was formed. Positive practice of pre-trial appeal against acts of tax authorities in terms of disputes on "business split” in favor of taxpayers under 54.1 of the Tax Code was formed.

  • Employee involved

    Olga Savina

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The reality of subcontractors' activities was proved and the claims of the tax authority were withdrawn.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

    Alexander Dmitriev, Yulia Pavlova, Olga Savina, Anastasia Garipova

Successfully

Defended the interests of the largest supplier of household appliances in arbitration court in a case of additional taxation of imported goods with the participation of the chain of resellers.

Court settlement of tax disputes

Exclusion by the tax authority of material evidence against a disputed counterparty of a major supplier of household appliances

  • Industry

    FMCG

  • Process description

    With regard to the client, a tax audit was carried out, as a result of which the tax authority provides evidence that the audited entity actually purchased the disputed products directly from the importer bypassing the chain of suppliers. One of the evidence of fictitiousness was the protocol of inspection of warehouse and office premises, which the tax authority established the absence of this counterparty at the addresses and concluded that the supplier could not store the goods. The lawyers collected the information proving the falsification of the evidence submitted by the tax authority.

  • Result

    In the course of the court proceedings, the tax authority excluded this evidence, which initially formed the basis for the tax audit decision, from its position.

  • Employees involved

    Andrey Solomyany, Olga Savina

135 mln ₽

Challenging additional charges to a major retailer in a case concerning the application of tax deductions for VAT on recycled goods

Court settlement of tax disputes

Claims tax authority was made in connection with the unjustified inclusion in the composition of VAT deductions and profit tax costs incurred in the relationship with the disputed supplier, as well as the improper application of VAT deductions for recycled goods.

  • Industry

    FMCG

  • Process description

    The tax authority charged the grocery retailer additional VAT and income tax on the fruit supplier, citing the impossibility of tracing the goods from the importer to the final supplier for this delivery, as well as the presence of formal claims against the supplier. Also in connection with the fact that the fruit supplied was of improper quality and disposed of by the client within the same tax period, the tax authority further argued the impossibility of applying VAT deductions due to the lack of the object of taxation. Translated with www.DeepL.com/Translator (free version)

  • Result

    As a result, claims of the tax authorities were successfully challenged in the arbitration court after the second round of judicial appeal since the Tax Compliance lawyers managed to prove the reality of transportation of fruits from the importer to the disputed supplier. They also provided a technological description of the utilization of the goods and the validity of the VAT deduction for the disputed transaction. Translated with www.DeepL.com/Translator (free version)

  • Employees involved

    Andrey Solomyany, Olga Savina

135 mln ₽

Defending a Russian construction company in an arbitration court at the stage of inclusion in the register of a tax authority claim in a bankruptcy case

Court settlement of tax disputes

Originally included in the register, the tax authority's claim was excluded due to the absence of tax arrears for the taxpayer.

  • Industry

    Construction

  • Process description

    As part of the bankruptcy proceedings, the tax authority's claim in the amount of RUB 135 million was included in the register of creditors' claims. The lawyers prepared a position with regard to this debt, namely: due to the fact that updated tax returns for VAT and income tax were filed, the amounts of claims must be adjusted, as the amounts payable on tax returns were initially filed by the previous management mistakenly.

  • Result

    The Moscow City Arbitration Court annulled the decision to include the tax authority's claim in the register of creditors' claims and the court appointed a new consideration taking into account the evidence provided.

  • Employees involved

    Andrey Solomyany, Olga Savina

Publications

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