Eduard Giulbasarov for Glavbukh Magazine No. 8/2024
A company is unlikely to fully insure itself against a ‘typical’ violation, however it is possible to reduce these risks. Practising tax lawyers and consultants have told us how to make it happen.
Find out what favourably distinguishes your situation from a ‘typical’ one.
“Always remember that although tax authorities often try to impute ‘typical’ violations, the activities of different companies are rarely typical — even within the same industries. Every company has its own specifics, both in terms of business and tax policy. Bearing this in mind, you should always bring to the tax officials’ attention the factors that favourably distinguish your situation from the typical model which the tax authorities are trying to impute,” explained Eduard Giulbasarov, Head of Practice of the Transaction Tax Structuring Department at FBK Legal.
Find out what favourably distinguishes your situation from a ‘typical’ one.
“Always remember that although tax authorities often try to impute ‘typical’ violations, the activities of different companies are rarely typical — even within the same industries. Every company has its own specifics, both in terms of business and tax policy. Bearing this in mind, you should always bring to the tax officials’ attention the factors that favourably distinguish your situation from the typical model which the tax authorities are trying to impute,” explained Eduard Giulbasarov, Head of Practice of the Transaction Tax Structuring Department at FBK Legal.
