Obtaining the first positive example in arbitration practice of exercising the right to account for a profit tax loss of more than 3.3 billion rubles, the use of which was initially refused as a result of the reclassification of loan relations into investment, and the operation of offsetting a loan with interest against a contribution to the Criminal Code – in debt forgiveness. — MAXIMA LEGAL

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Obtaining the first positive example in arbitration practice of exercising the right to account for a profit tax loss of more than 3.3 billion rubles, the use of which was initially refused as a result of the reclassification of loan relations into investment, and the operation of offsetting a loan with interest against a contribution to the Criminal Code – in debt forgiveness.

Context

Obtaining the first positive example in arbitration practice of exercising the right to account for a profit tax loss of more than 3.3 billion rubles, the use of which was initially refused as a result of the reclassification of loan relations into investment, and the operation of offsetting a loan with interest against a contribution to the Criminal Code – in debt forgiveness.

Selected cases

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Development of an alternative corporate structure of the business, the value of assets of which exceeds 4.6 billion rubles, to optimize tax costs when relocating part of the business to the UAE, Kazakhstan and Turkey.

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