Our team informs you that on February 12, 2021, the Federal Tax Service, in Letter No. ШЮ-4-13 / 1749 @, published additional clarifications on tax administration of expenses incurred by Russian companies purchasing intra-group services. These additions logically continued the position of the Federal Tax Service dated August 6, 2020 (“On certain issues of taxation of intra-group services” No. ШЮ-4-13 / 12599 @) and established approaches to the definition of joint-stock activities.
In its new letter, the FTS names the main characteristics of the shareholder activity and gives examples, dividing it into business planning and control activities and activities related to the strategic management of the group.
Why is this question important? The fact is that compensation of expenses for shareholding activities in expenses for tax purposes is not recognized, in contrast to expenses for services.
This letter is universal in nature and applies to both international groups of companies and Russian holding groups.
The specialists of the Sterngoff Audit company will be happy to provide consulting support in this matter, just contact us by e-mail info@sterngoff.com.
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