Over the past few years, the Russian tax authorities have paid close attention to intra-group expenses.
Federal tax service has published two guidelines of the tax audit of intra-group services payments during last half year. We have insights that several tax inspections have started tax audits on the matter by the order of the central office of Federal tax service. The accounting of such expenses for tax purposes with no detailed documentation will lead to tax risks on the corporate profit tax, VAT, WHT (as the payment may be re-qualified to the hidden dividends).
BakerTilly lawyers have deep understanding of the issue and multiple experience of defending such expenses. BakerTilly legal team bring to your attention it`s research of the issue systemizing the requirements of tax authority and approaches of arbitration practice.
If you are looking for cooperation with BakerTilly legal practice on that topic, please contact Revaz Chitaya (Revaz.Chitaya@bakertilly.ru,) or your personal manager.
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