The company is accused in business fragmentation. How to win a case against the Federal Tax Service

Oktober, 2024 | Published
Authors: Kruglova Lyudmila, Kovalevich Alexander
Dangerous signs of business fragmentation that the Federal Tax Service notices. Only a quarter of decisions are made in favor of taxpayers, and a single IP address can become a reason for an audit.

In this article we will discuss:
  • what the courts and tax authorities mean by business fragmentation;
  • what signs of fragmentation are most often referred to by tax authorities;
  • how to determine the beneficiary in a business splitting scheme;
  • what signs of interdependence of persons are the most difficult to challenge in court.
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