tax alert Risks of intercompany financing Today we released a review of a rather interesting tax dispute. Almost 3 billion rubles was added into a taxpayer’s income, which was received by him from a holding company. First instance…
lawmaking Antics of tax administration improvements Last week, the State Duma adopted so many drafts on taxes that there will be enough work for a whole generation of consultants. But we’re not talking about them. I would like…
transfer pricing New signs of related party The tax authorities’ attempts to make up new grounds for recognition of individuals as interdependent have been known since the times of art. 20 of the RF Tax Code, which rests in peace…
tax residency The daughter-in-law tax test In international practice, in order to determine what country a natural person is a resident of, various tests are applied (tie-breaker rules). These include: Centre of vital interests test Permanent home test Habitual…
lawmaking The story of one of the bill The lack of transparency of legislative activity in the Russian Federation has become proverbial. And we are talking here not so much about the process but about documenting and transparency of amendments justifications,…
tax alert New format of tax alerts Dear colleagues, you must receive a great number of tax alerts and other information materials. So do we ;-) But we’ve decided to experiment a little with the format. And here’s…
penalty Made-up fines Back to... Do you remember the case of "Dalsvayz ? Probably not. That was 6 years ago. Back then, the tax authority requested the taxpayer to provide 14,153,291 document copies, which,…
case study About the judge's dyslexia It is no surprise that a large number of judicial decisions are made via copy-pasting. This can be treated as a certain stage in the evolution of the judicial system. They just cannot…
