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

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.