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New risks associated with assets restructuring within holding companies

On 13 February 2017 Commercial court of Vladimir region (hereinafter – the “Court”) adopted decision in a tax dispute case № A11-6203/20161 (hereinafter – the “Decision”). If the Decision is upheld by appeal court, this might induce supplementary risks of tax non-compliance in the area of asset restructuring.

The Decision was rendered in a tax dispute between “Mon’delez Rus” LLC (subsidiary of Kraft Foods Inc. (USA) holding company) (hereinafter – the “Company”) and a Major Taxpayers’ Interdistrict Tax Office of Federal Tax Service in Vladimir region (hereinafter – the “Tax office”). In its resolution dated 18 December 2015 the Tax Office found the Company liable for tax non-compliance: the Company, inter alia, was charged with an additional tax payment in the amount of RUB 514 million.

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