Galina Akchurina, FBK Legal Partner and Head of Tax Litigation Practice, has been a moderator and a speaker at the session titled “Novelties in Tax Legislation and Administration” held as part of the Twelfth Tax Congress.
Practicing lawyers and partners of big law firms shared their experience at the session. They discussed price control for tax purposes, reviewed precedents of pre-trial settlement of tax disputes and possibility of automatic exchange of financial information about international groups.
In particular, the discussion covered price control in uncontrolled transactions after cancellation of Art. 40 of the Tax Code of the Russian Federation. Related parties that carry out transactions totalling over RUB 1 billion a year have guarantees of rights protection. There are no statutory methods or restrictions for sources of information in respect of price control in uncontrolled transactions. As a result, in practice there are different control methods, different “market rates” for each taxpayer. This is in violation of fundamental principles of legal certainty and equality in taxation. One of the central topics of discussion was how to protect rights of taxpayers in such a situation.
The forum gathered financial directors, managers and specialists of tax planning departments, heads of tax departments, chief accountants and tax lawyers of big companies, as well as managers of tax practices, partners and heads of business development of audit, law and consulting firms.