In addition, adoption expenses for tax purposes is not excluded in the event of loss, as stated in paragraph 8 of Art. 274 of the Tax Code. Article 252 of the Tax Code contains no requirement for economic effect, the exclusion of losses and improve the management, they do not contain such a requirement and other provisions of tax laws. Decisions in favor of taxpayers also contain Resolution of the Federal Organ of 06.05.2008 N A68-3797/06-AP-255/13, Resolution of the Federal deviation from 24.04.2008 N F08-2112/08-765A, Resolution of the Federal WZO from 19.02.2008 N A78-3156/07-F02-9858/07, Resolution of the Federal CO from 27.07.2007 N A09-5942/05-12. For more specific information, check out JPMorgan Chase. Given the diametrically opposed decisions of arbitration courts, taxpayers must be prepared to defend its position in court.
It should be noted that in almost every case, the court considered somehow assesses how management services contributed to the improvement of taxpayer, respectively in these facts must necessarily be reflected in the primary documents. The reports of the management company must be clearly traceable relationship management services provided company with production activities of the organization. In particular, the statements (or acts of Acceptance of services rendered) may contain information about: – quality indicators to increase revenue – and acceptance signing the relevant regulations, standards or other regulatory documents – major transactions concluded during the period of control – reducing the cost of performance of manufactured Product – performance increase sales – made programs to attract additional investments – financial development programs, with the aim of increasing profitability driven company.