Article by FBK Legal Expert Evgeny Timin for "Practical Tax Planning" Journal No. 3, 2025

31 March 2025

Evgeny Timin, Senior Lawyer at the Tax Services Department of FBK Legal, discusses possible solutions in case additional taxes are assessed due to the “incorrect” transition to RFAS 6/2020.

Evgeny Timin has contributed an article to the “Practical Tax Planning” Journal No. 3, 2025, where he addresses the relevant issue of transition to RFAS 6/2020. In the article he covers:

  • Transition options to RFAS 6/2020 proposed by the Ministry of Finance of the Russian Federation

  • Cases in which tax inspectors raise objections

  • Key arguments to prove that the tax base was not misstated.

Inspectors have begun raising objections over property tax calculation. RFAS 6/2020 is the reason for this. Although it is an accounting standard for fixed assets, tax authorities scrutinise the companies’ transition process. Cases have been registered when the authorities accused the company of distorting the property tax base when switching to RFAS 6/2020. Such controversies often lead to additional tax assessments. While these claims are debatable, companies should be ready to challenge them with strong arguments. At the time of writing the article, no established arbitration practice exists on such controversies, which also increases risks for business.

Read the full article here.

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