Chief Tax Consultant
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.
38 million ₽ Representing a construction company in a field tax audit
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.
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.
Alexander Dmitriev, Yulia Pavlova
The reality of subcontractors' activities was proved and the claims of the tax authority were withdrawn.
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.
Claims of the tax authority on the field inspection report were appealed and withdrawn.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.
Alexander Dmitriev, Yulia Pavlova, Olga Savina, Anastasia Garipova
Transaction structuring and tax planning at FMCG group of companies
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.
As a result, successful structuring and tax planning efforts eliminated risks in excess of 80 million ₽.
Yulia Pavlova, Anastasia Garipova