To a company with foreign investments, which is a processor and exporter of sunflower oil, a tax office increased an object of taxation by profits tax in the amount of about 137 million UAH, based on violations committed by its counterparty. Wherein, a tax office emphasized that acts on agricultural products supply between the client and his counterparty were fancy (unjustifiable).
Due to the judicial concept formed by our team for our client, a detailed protection strategy was developed, a careful analysis of accounting and tax documentation was carried out. During the judicial examination, we provided hard evidence for confirming the reality of commercial transactions, the origin of goods, processing, and further realization. Despite the fact that the judicial practice in the mentioned disputes was formed not in a favor of taxpayers, our company proved the absence of a legal foundation for recognizing the testimonies of officials of the counterparty of the non-commodity transactions provided during the pre-trial investigation as competent evidence.
Due to the effective concept of protection of the client’s interests, which was realized in this case, the company prevented additional expenses because of unreasonably charged value-added tax and increasing the taxing object by the profits tax in the total amount of 137 million UAH.