Split of business as a way of tax evasion
The tax authorities often regarded business split as formal, with the aim of obtaining unreasonable tax benefit through artificial distribution of revenues from operation activity among controlled related parties. Recently has been developed court practice of challenging of decisions of the tax authorities, issued as a result of tax audit and establishing the fact of obtaining unreasonable tax benefit. In this article the main conclusions, based on analysis of such court practice, and options for taxpayers for recognition of justified tax benefit are formulated