Amnesty in case of fragmentation

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The 2025 tax reform will also affect the simplified tax system (STS). Within the framework of this regime, there will be an obligation to pay VAT if the organization's revenue exceeds 60 million rubles.

The Tax Code will provide taxpayers with the opportunity to choose the method of paying VAT:

payment of VAT at a rate of 5% (for revenues up to 250 million rubles per year) or 7% (for revenues from 250 million to 240 million rubles per year), but without the use of deductions;
payment of VAT at the standard rate of 20%, but with the use of deductions.
In connection with the introduction of VAT for taxpayers qatar telegram under the simplified tax system, the law also increased the thresholds that give the right to apply this regime.

Taking into account these changes, organizations and individual qatar telegram entrepreneurs need to assess the feasibility of applying the current tax regimes (simplified tax system/general tax system), consider the options proposed by law and choose the regime that will facilitate the most efficient conduct of business and reduce tax liabilities.



The 2025 tax reform introduces the concept of "business fragmentation". The law identifies the following signs indicating fragmentation:

division of a single entrepreneurial activity between formally independent persons;
control exercised by the same persons;
the main or primary purpose of the division is to reduce the amount of taxes;
Savings occur when individuals use special tax regimes.
The law also introduces an amnesty for using the business fragmentation scheme in 2022–2024. The amnesty applies in the event of voluntary refusal (in whole or in part) from the said scheme in relation to the periods 2025–2026. Accordingly, the periods 2022–2024 will be exempt from arrears, fines and penalties.

The amnesty mechanism is applied in the format of suspending the entry into force of decisions based on the results of inspections for 2022–2024.

The law provides various methods for applying or not applying the amnesty depending on whether the person uses the specified scheme in subsequent periods.

Groups of companies need to assess their businesses for signs of fragmentation, such as :

actual control by one person;
unified accounting or tax service;
single IP address;
single registration address/actual address;
single counterparties;
single type of activity, etc.
Before deciding on the possibility of an amnesty, it should be borne in mind that the sanctions for using the splitting scheme are quite serious. In particular, additional taxes are charged as if the companies were operating as a single business, as well as a 40% fine and penalties on the entire amount of taxes underpaid to the budget.