The professional publication ‘Advokatelskaya Gazeta’ published an article by Alexander Sergeyev, Managing Partner of the Moscow Law Office ‘Alliance Legal’.
The illegal scheme must be abandoned by 1 January 2025.
It is not necessary to declare the renunciation. After that date, a business must not receive an unjustified tax benefit from the split.
Amnesty is provided for companies and entrepreneurs who used business splitting for tax optimisation. If they voluntarily abandon such a scheme, the tax authority will write off the taxes, penalties and fines that were accrued due to the split (Federal Law No. 176-FZ dated 12 July 2024).
The amnesty applies to the amounts additionally assessed after audits for 2022-2024, the decisions on which have not entered into force by 12 July 2024.