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ACCENTS OF TAXIS DURING THE REALIZATION OF REALITY OF PERFORMANCE OF ECONOMIC OPERATIONS

 In the course of its audits, the Department of Tax Audits, Transfer Pricing and International Taxation pays special attention to the study of the origin of the goods (works, services) acquired by the entity, the reality and the possibilities of its operations.

 In particular, the verification of the reality of an entity’s transactions shall focus on:
– data on the origin of goods (whether manufactured, by whom and when, the presence of manufacturer’s certificates and origin);
– data on the movement of goods from the supplier to the buyer (transportation, storage, acceptance, including the establishment of officials involved in the process);
– data on the use of acquired TMCs in the further activity (realization (export), participation in own production process or economic activity);
– proof of receipt of the asset (TMC) exactly from the supplier’s specified counterparty documents;
– explanation of the officials (representatives of the officials) of the contracting parties – suppliers about the reality or unreality of a certain operation (providing by a third party explanations and their documentary confirmation in full at the request of the controlling authority for conducting counter-verification);
– information on the history of business relations between the taxpayer and his counterpart;
– evidence of the technical feasibility of performing an economic operation, taking into account the actual economic resources of the supplier (availability of production facilities, personnel, premises) and the actual content of the operation (whether special skills of personnel are required to perform it, or sufficient own or involved means, time and special equipment, etc.) ;
– the presence of a contracted employee’s staff or relevant subcontracts with third parties.

 The analysis of these data leads to the conclusion about the reality of operations carried out by the entity for the purchase of goods (works, services).

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