On 12 July 2024 an amnesty for business splitting was announced. In practice, quite a few questions have arisen as to who may count on the amnesty, and in which case.
A number of important conclusions from the recommendations of the Federal Tax Service:
1. A condition for applying the amnesty is a voluntary refusal to split the business for 2025-2026:
2. A voluntary refusal to split may be carried out by changing the organisational structure of the business, or without such a change.
3. The amnesty does not apply if:
• the taxpayer has not refused to split in 2025-2026;
• the splitting was identified for periods of 2021 and earlier;
• a decision following a tax audit for the periods 2022-2024 entered into force before 12 July 2024;
4. A taxpayer may use the amnesty for 2022-2023 on condition that he has refused to split for 2024, 2025 and 2026 before a decision is issued on the results of the audit for 2025 and 2026.
5. A taxpayer is entitled to inform the tax authorities of a voluntary refusal to split.
Follow Consul Group on Telegram.
.jpg)
Analytics
Events