Not a single share ... And again about the motivation of top managers
Increasingly, we are faced with a request from business founders: we want to give top managers shares so that they receive a percentage of profits and are associated with the…

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Mistakes and risks of financing in the group of companies
You may already be familiar with our analytics on allegations of artificial business splitting, which covered all tax arbitration disputes in the context of "business splitting" in a complete manner.…

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Control of operations with cash and property
The institution of mandatory control over transactions with money and other property is one of the basic elements of the functioning of the Russian system for countering the legalization and…

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On the preparation of an investment declaration by a SEZ participant
In accordance with Part 2 of Art. 13 of the Federal Law of 29.11.2014 No. 377-FZ "On the development of the Republic of Crimea and the federal city of Sevastopol…

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Transport services in the Group of Companies
In the issues of our mailing list, we have repeatedly written about the separation of the company - Custodian of Assets in order to protect the significant property of the…

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regular return

Mistakes and risks of financing in the group of companies

You may already be familiar with our analytics on allegations of artificial business splitting, which covered all tax arbitration disputes in the context of “business splitting” in a complete manner. In 2017-2019 (we are ending 2020), there were about 350 cases that went through three instances in court.

The analysis gave us the basis to identify 30 signs of artificial fragmentation of the business, which we were able to rank according to the degree of their “killer”. You can find all the analytics on this issue in the corresponding Guide. Continue reading

The third rule for building a group of companies without signs of artificial fragmentation.
Let's turn to business process notation again. Earlier we decided on the inputs, the activity itself, and the outputs (goals). However, in arbitration practice on artificial fragmentation of a business,…

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Progressive tax rate
Tax base and set of tax bases When determining the tax base, all incomes of an individual that are received by him both in cash and in kind or the…

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When you can't do without an agency agreement
We have repeatedly talked about the pros and cons of an agency agreement (see, for example, here), pointing out the need for a deliberate approach to the use of the…

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