10-07-2009, 06:04 PM
Dear colleagues, in the framework of my currently scientific activities I am developing proposals for amendments in Tax Code of Russian Federation. The aim of the changes - to increase the distinctness of the concept of reasonable expenses of taxpayer to the corporate tax computation. In the Russian Federation, there are many disputes subject becomes claimed taxpayer expenditures. The tax authorities are trying to increase the corporate tax obligations of the taxpayer's through the recognition of his expenses waste (unreasonable expenses). Even in cases where this waste can have a business purpose. Courts resolve this category of disputes differently. Uniform judicial practice of this issue has not formed.
I urgently require information about practice of considering such disputes in foreign States (anyone).
For instance, disputes about buying expensive (luxury) equipment (permanent assets) to replace existing equipment, which can be used more for several years, but obsolescenced.
Russian Tax Code actually include requirements only about business purpose and documentation of expenses and say nothing about reasonable price of goods and servises.
I would particularly grateful for the references (links) to judicial decisions, explanations of supervisory tax services and laws.
Thank in advance all for participation. I hope that this work will be usefull and taxpayers in Russian Federation will be able to feel themselves easy.
I urgently require information about practice of considering such disputes in foreign States (anyone).
For instance, disputes about buying expensive (luxury) equipment (permanent assets) to replace existing equipment, which can be used more for several years, but obsolescenced.
Russian Tax Code actually include requirements only about business purpose and documentation of expenses and say nothing about reasonable price of goods and servises.
I would particularly grateful for the references (links) to judicial decisions, explanations of supervisory tax services and laws.
Thank in advance all for participation. I hope that this work will be usefull and taxpayers in Russian Federation will be able to feel themselves easy.