The Problems of Applying Special Taxation Regimes by Participants in a Group of Companies

This scientific research is devoted to the issues and problems of applying special taxation regimes by participants in a group of companies. The purpose of the study is to identify issues in the sphere of using special taxation regimes by companies which are in correlation with each other, as well as develop ways to solve the problems identified and suggestions of improving the current legislation. The following tasks were set and completed: The concepts of “interdependence”, “business fragmentation” and “unjustified tax benefit” were analyzed, the main mistakes made by taxpayers using business fragmentation were identified, the positions of courts and tax authorities regarding criteria for legitimacy of applying preferential tax regimes were analyzed, gaps were identified and suggestions for improvement current tax legislation in the area of application by the group of companies of special taxation regimes were made.