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Federal Defense

January 6, 2019 in News Tags: ,

In order to minimize tax risks in the design of primary source documents and reflected in the accounting and tax expenditures on services management company, subject to the arbitration practice, need to pay attention to the following: – the decision to transfer authority of the sole executive body of the management company must be made by shareholders of society, that is, persons who most interested in maximizing the profits of the company, with the decision about signing a contract for the provision of management services should be justified (for example, due to declining sales, search new markets and upgrade the range of products, etc.) (Resolution of the Federal Defense of 28.05.2007 KA-A40/4360-07) – function of the management company should not duplicate the duties of managerial staff society and should be aimed at generating income (Resolution of the Federal Defense of 28.05.2007 KA-A40/4360-07, Resolution of the Federal WZO from 25.04.2006 on case number A19-18184/05-40-F02-1722/06-S1 ) – the fact of delivery must be documented (order approving staffing, accounts for payment, money orders, acts of completion, signed agreements on financial and economic activities, human resources documents, documents on the Planning and Economic work and developed a management company directives, instructions, standards, the taxpayer, etc.) (Decision of the Central Organ of the FAS 27.07.2007 A09-5942/05-12 FAS UP from 28.09.2007 F03-A04/07- 2 / 3831) – in the contract (or for additional agreement) must be approved by the technique of determining the cost of management services. Despite the fact that the tribunals do not consider the absence of evidence of a lack of technique feasibility study associated costs (Resolution of the Federal vivo from 27.09.2006 on case number F09-8635/06-S7), the presence of the parties agreed methodology will serve as an additional argument in favor of the taxpayer. Learn more at this site: Areva. . . Here, crowne plaza rosemont expresses very clear opinions on the subject.


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