The performance from year to year

Dispute with the Tax Authority regarding the reality of product transportation

Objective

Our client, a large company engaged in the wholesale trade of alcoholic beverages, requested assistance in a dispute with the Tax Authority on additional tax assessment for the product transportation. The Tax Authority considered that the counterparty who transported alcoholic beverages for our client would not have been able to do so, and the client unreasonably reduced the tax base by the amount of costs for the performed transportation. The project was important for the client, since in the event that the claims of the Tax Authority were recognized reasonable, the client would have to pay in addition to the budget about 100 million rubles of taxes and fines.

Decision

We have engaged in the project stage when the Tax Authority was preparing an act based on the results of a field tax audit. At the stage of consideration of objections to the Tax Authority and later on during the court hearings, we proved the reality of the performed transportation, the availability of economic benefits and the client's due diligence and caution. As a result, we were able to achieve recognition of the Tax Authority decision fully invalid. Despite the fact that the Tax Authority managed to revoke the decision in the appeal court, we defended the legality of the court decision of first instance in the cassation court.

Result

The client was able to prove its due diligence, save more than 100 million rubles, and save on the costs of changing the system of the product transportation.

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Project team

Roman Gusak Attorney-at-law

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