Lawyers of FBK Legal holding workshop for the subsidiary of Gazprom OJSC.
Workshop on the subject ‘Alterations in tax law. Actual tax disputes’ was held by the lawyers of FBK Legal for the employees of Gazprom Dobycha Yambourg LLC. The workshop was attended by FBK Legal partner and head of Tax Resolution practice, Galina Akchurina, expert Alexander Grigoryev and chief consultant Maria Kasapova.
Issuance of tax invoices and registration of the same was discussed in details, claims advanced by tax authorities and resolved by arbitration courts in relation to VAT and corporate income tax were analyzed, specific issues of interrelation and taxation of consolidated group's income and some other aspects were considered by the lawyers.
In particular it was discussed what kind of costs may be allocated to research and development works for tax purposes. The lawyers of FBK Legal mentioned general criteria to be applied for such allocation. Those are availability of contract, technical specifications for such works and novelty of technological solution, not yet mentioned in the available technical (geological) documents.?
‘It’s a question frequently asked by the companies, if the costs shall be recognized as research and development or general costs. The RF Supreme Court of Arbitration has recently solved this question by its award, specifying that allocation of the costs that for the equal grounds may be allocated to the different groups of costs may be decided upon by the taxpayers themselves’,- Galina Akchurina said. Taxation of servicing companies has also attracted significant interest.
Gazprom Dobycha Yambourg LLC is a 100% subsidiary of Gazprom OJSC.
Gas and gas condensate production, performance of geological exploration works, development and exploration of new gas and gas condensate fields, oil deposits in Yamalo-Nenetsky Okrug. The company has permissions for development of five fields. Over 2000 of gas and gas condensate wells are now developed by the company.
Issuance of tax invoices and registration of the same was discussed in details, claims advanced by tax authorities and resolved by arbitration courts in relation to VAT and corporate income tax were analyzed, specific issues of interrelation and taxation of consolidated group's income and some other aspects were considered by the lawyers.
In particular it was discussed what kind of costs may be allocated to research and development works for tax purposes. The lawyers of FBK Legal mentioned general criteria to be applied for such allocation. Those are availability of contract, technical specifications for such works and novelty of technological solution, not yet mentioned in the available technical (geological) documents.?
‘It’s a question frequently asked by the companies, if the costs shall be recognized as research and development or general costs. The RF Supreme Court of Arbitration has recently solved this question by its award, specifying that allocation of the costs that for the equal grounds may be allocated to the different groups of costs may be decided upon by the taxpayers themselves’,- Galina Akchurina said. Taxation of servicing companies has also attracted significant interest.
Gazprom Dobycha Yambourg LLC is a 100% subsidiary of Gazprom OJSC.
Gas and gas condensate production, performance of geological exploration works, development and exploration of new gas and gas condensate fields, oil deposits in Yamalo-Nenetsky Okrug. The company has permissions for development of five fields. Over 2000 of gas and gas condensate wells are now developed by the company.