Successful defence of a company in a dispute with a taxation authority
Successful defence of a company in a dispute with a taxation authority in one of the largest disputes (the amount of claims is more than RUB 4 billion) for the last five years in the Siberian Federal District
At the pre-action stage, we proved the economic validity of the business model of the company’s activities and the absence of violations of the transfer pricing rules in coal supplies, which ensured the taxation authority’s voluntary withdrawal of 98.3% of its tax claims. For the remaining additional taxes (1.7%), the imputed violation was reclassified, as a result of which the client was almost completely exempted from tax liability, which excluded criminal risks.
