01
Verification is won at the time the evidence is created
After the inspection request, you cannot limit yourself to uploading documents. The team connects the contract, business goal, choice of counterparty, actual performers, movement of goods or results of work, payments, accounting and tax accounting. For each episode, a single evidence file is generated and a list of gaps that can still be legally eliminated.
- Pre-test analysis
- Counterparties, gaps, discrepancies, unprofitability and non-standard transactions
- Response to requirement
- Only verified evidentiary version and controlled volume of disclosure
- Interrogations
- Training employees on facts without memorized answers and assumptions
- Expertise
- Calculations, industry standards, volumes, routes, technical feasibility and price
- Position protocol
- Consistent facts for accounting, lawyers, employees and external consultants
02
A disputed contractor is a dispute about the actual performance and knowledge of the taxpayer
In disputes over VAT and income tax, the inspectorate examines not only a set of primary documents. What matters is the actual actor, chain resources, diligence, business purpose, movement of money, goods and personnel, and whether the taxpayer knew or should have known about the circumstances of the violation. The defense must explain the entire operation, not just the formal first link.
Who, where, when and with what resources performed the work or delivered the goods.
Why the counterparty was chosen and what information was checked before the transaction.
Business purpose, price, margin, production need and further use of the result.
Not only qualifications are checked, but also the correctness of the amount of additional charges and reconstruction.
03
The pre-trial stage is an independent trial, not a formality
Objections to the act, participation in the consideration of materials, additional activities and an appeal are designed as a consistent system. We separate errors of fact from errors of law, prepare an alternative calculation, show contradictions in the inspection evidence and leave in the case everything necessary for a future trial.
- 01Episode Map
Amount, tax, period, counterparty, inspection evidence and our response.
- 02Objections
Facts, law, applications and motions without internal contradictions.
- 03Consideration
Oral position, recording violations of procedure and requesting additional actions.
- 04Complaint
Priority grounds for cancellation, alternative calculation and judicial readiness.
04
What is proven in court is not a folder of documents, but a coherent business history
Trial strategy integrates the subject matter of the dispute, the burden of proof, the admissibility of evidence, witnesses, experts and economic calculation. We determine in advance which conclusions of the Federal Tax Service’s decision are refuted by the document, which by testimony, which by industry expertise, and where legal qualifications are required.
Contradictions in individual links and tax violations of the supplier do not in themselves cancel the confirmed fact of receipt and use of real goods. The center of the defense is the entire set of facts of the operation.
05
Results that can be verified or measured
Case No. A40-71125/2015, determination No. 305-KG16-10399. The main additional charges for VAT and income tax related to claims against the supplier and the coal movement chain were disputed. The Supreme Court restored the findings in favor of the taxpayer.
Public court caseThe project's lead lawyer accompanied the review of a major subsidiary of an energy group. Based on the results of work with episodes, evidence and calculations, the volume of claims was reduced by approximately 600 million rubles before a final decision was made.
Client not disclosedDispute over VAT and income tax due to claims against contractors. Actual production needs and execution have been proven; potential additional charges were reduced by approximately 350 million rubles.
Client not disclosed06
What to submit for initial assessment
- 01
Requirements, act, decision, additions and protocols of control measures.
- 02
Contracts, primary documents, correspondence and evidence of actual execution.
- 03
Turnover balance sheets, purchase and sales books, inspection calculations.
- 04
Information about the selection of contractors, tenders, inspections and responsible employees.
- 05
Calendar of deadlines and information about the current stage of review or appeal.