"Business fragmentation " in the conditions of 2018: deployment from the payment of taxes or validity?

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The article analyzes the practice of arbitration courts and explanatory letters from regulatory bodies concerning disputes related to the «business fragmentation», examines the consequences of recognizing the «business fragmentation» unfounded, aimed at creating conditions for obtaining unreasonable tax benefits. Examples of a business at risk are given, generalizations from judicial practice of 2017-2018 are made. The author recommends what it is necessary to pay attention to when conducting activities in the conditions of interdependence of legal entities.

Business fragmentation, tax optimization, litigation practice in business fragmentation cases, interdependence of legal entities, imitative feature of intent

Короткий адрес: https://sciup.org/170172938

IDR: 170172938

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