Question to a specialist

A: The Decree as of 12.10.2006 #53 of HAC Plenum of RF introduced an understanding of baseless tax profit, and also criteria for acknowledgement of tax profit, received by taxpayer. HAC of RF interpreted that tax profit can be considered as baseless in case if for taxation purposes operations not corresponding to their actual economic meaning or operations not substantiated by logical economic or other reasons. Besides, the tax profit cannot be considered baseless if it was received by taxpayer not in connection of entrepreneurship or any other economic activity.

Court practice developed the following main criteria of unconscientiousness – actions of arrangement participants directed solely at VAT reimbursement.