Result: 75% of additional taxes, penalties and fines were challenged at the pre-trial stage

2 650 000

rubles, project cost
ANP Zenit

42 700 000

rubles, disputed tax additional charges

1 511%

Return on investment (ROI)

The Federal Tax Service conducted an on-site tax audit of a dairy processing plant. The essence of the claims of the tax authority was reduced to the creation of a formal document flow with counterparties in the actual purchase of milk from individual entrepreneurs and organizations applying special taxation regimes.

Having studied all the materials of the tax audit, we were able to prove that during the on-site audit, the tax authority collected comprehensive evidence of the reality of business transactions with disputable counterparties.

We also identified gross procedural violations of the tax authority, namely:

  • the disputed decision was made by the head of the tax authority, who did not participate in the consideration of the audit materials and the taxpayer's objections;
  • the decision was made with a delay of 22 months, such unlawful delay led to an increase in penalties by almost half.

Pointing out these violations significantly strengthened our position and made it possible to achieve the cancellation of most of the additional charges at the pre-trial stage.

Pre-trial appeal of the results of the tax inspection of a dairy processing plant
Guzel Valeeva
Senior Partner

Completed projects

Pre-trial appeal against the results of an on-site tax audit of a large construction company

Result: 87.1% of additional charges were withdrawn at the stage of consideration of tax audit materials and making a decision

Сопровождение выездной налоговой проверки крупной строительной компании

Результат: размер потенциального доначисления снижен более чем на 20 млн. рублей