Protect your company from tax claims - rate 9,900 rubles. from KonturSchool, training 7 hours, Date: December 7, 2023.

How tax authorities prove business fragmentation in 2022

What is business fragmentation?
-Fragmentation of business from the point of view of courts
-Fragmentation of business from the point of view of tax authorities
-Concerted actions of the taxpayer and affiliated persons
-Tools for proving business fragmentation
-Responsibility for business division

Signs of business fragmentation
-Negative signs of business fragmentation for taxpayers
-Neutral signs of fragmentation, according to arbitration courts
-Does the division of a business prove a common address?
-Does the division of the business prove a common brand?
-Do common founders prove the division of the business?

-Does the division of a business prove a shared telephone number?

Reducing the risks of blaming business fragmentation

-Reality and independence of taxpayers’ activities
-Business goal of creating new organizations and individual entrepreneurs
-Market conditions for transactions between related parties 
-Is it possible to return an overpayment to an affiliate if accused of splitting a business?
-How expenses are taken into account in case of accusations of business fragmentation 
-How to eliminate signs of business fragmentation

Schemes for obtaining unjustified tax benefits
-Increase in property value.
-Use of tech companies
- Factoring agreement
-Hidden implementation
-Reducing the tax base for income tax by recognizing a penalty
-Agency schemes
-Answers on questions
Online test