Why might a tax-free transfer of property be required? The change of ownership of property by concluding a sale and purchase agreement is recognized as a sale and entails the need to pay VAT and income tax (when applying the general taxation system). In the event that the property is transferred in a single group of companies, the occurrence of tax liabilities is highly undesirable: in fact, the property remains in the ownership of the same beneficiary, and taxes must be paid. In addition, a tax-free transfer (change of ownership) of property in a group may be required:
To increase the level of property security. Obviously, “vital” property for the business should not be in the operating sector. Continue reading
Quite often, we see an “internal IT company” in the business structure, which performs a different range of functions – from developing on the 1C platform or writing proprietary warehouse accounting programs to ensuring the performance of websites and the rest of the infrastructure. And, of course, we could not ignore the IT tax maneuver, which resulted in changes to the conditions for applying reduced rates for insurance premiums.
Why create an internal IT company Continue reading
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