Tax security in case of risks of business fragmentation by retail entities
Abstract
The article is devoted to the study of business fragmentation issues in the system of economic security of retail trade organizations in order to minimize the tax burden. Small enterprises, related to retail trade according to OKVED, form the most common business cluster and, as a rule, apply a special tax regime. Large trade turnover in the retail business currently allows the state to increase the tax burden for it. It is the increase in the tax burden that gives impetus to entrepreneurs to fragment their businesses and apply various "gray" taxation schemes. The authors present an economic interpretation of the tax consequences for economic entities in retail trade and an analysis of the fiscal burden with an increase in the tax burden.
About the Authors
I. A. Svetkina
Samara State University of Economics
Russian Federation
Russian Federation
Irina A. Svetkina – Candidate of Economics, Associate Professor, Associate Professor of the Department of Accounting, Analysis and Economic Security
Samara
N. S. Sakhchinskaya
State University of Social Sciences and Education
Russian Federation
Russian Federation
Natalya S. Sakhchinskaya – Doctor of Economics, Associate Professor, Professor of the Department of Economics and Economic Security
Samara
References
1. The Tax Code of the Russian Federation (Part one) dated 31.07.1998 No. 146-FZ. URL: https://www.consultant.ru/document/cons_doc_LAW_19671/eab507d8eb4d9c9196ed3567f9f3ee98dd0c2f76/#dst1529 (date of access: 25.01.2025).
2. On amendments to Parts One and Two of the Tax Code of the Russian Federation, certain legislative acts of the Russian Federation and invalidation of certain provisions of legislative acts of the Russian Federation : Federal Law dated 12.07.2024 No. 176-FZ. URL: https://www.consultant.ru/document/cons_doc_LAW_480697/ (date of access: 25.01.2025).
3. On abuse of tax advantages established for small businesses : Letter from the Federal Tax Service of Russia dated 29.12.2018 No. ED-4-2/25984. URL: https://normativ.kontur.ru/limited/documents/34360066858 (date of access: 25.01.2025).
4. On the direction of the review of judicial practice related to the appeal by taxpayers of non-normative acts of tax authorities issued as a result of tax control measures, during which the facts of obtaining unjustified tax benefits through the formal division (fragmentation) of business and the artificial distribution of proceeds from activities to controlled interdependent persons were established : Letter from the Federal Tax Service of Russia dated 11.08.2017 No. CA-4-7/15895@. URL: https://normativ.kontur.ru/limited/documents/34360038263 (date of access: 25.01.2025).
5. On the legal positions formed by judicial practice and applied by arbitration courts in resolving disputes related to the establishment of signs of "business fragmentation" in the actions of taxpayers : Letter of the Federal Tax Service of Russia dated 07/16/2024 No. BV-4-7/8051@. URL: https://www.consultant.ru/document/cons_doc_LAW_481104/ (date of access: 25.01.2025).
6. On countering the legalization (laundering) of proceeds from crime and the financing of terrorism : Federal Law dated 07.08.2001 No. 115-F. URL: https://www.consultant.ru/document/cons_doc_LAW_32834/ (date of access: 25.01.2025).
7. Bryantseva L.V., Bicheva E.E. Tax risks in the economic security system // Modern economics: problems and solutions. 2024. No. 8 (176). Pp. 94–106. doi:10.17308/meps/2078-9017/2024/8/94-106.
8. Alexandrova E.A. Analysis and management of tax risks in the organization's tax security system // Economics and entrepreneurship. 2024. No. 10 (171). Pp. 1307–1313. doi:10.34925/EIP.2024.171.10.239.
9. On Amendments to the Order of the Federal Tax Service of Russia dated 24.03.2023 No. ED-731/181@ "On Approval of the Methodology for assessing a legal entity based on the interactive service "Personal Account of the taxpayer of the legal entity "AIS "Tax-3" : Order of the Federal Tax Service of Russia dated 17.05.2024 No. ED-7-31/398@. URL: https://www.consultant.ru/document/cons_doc_LAW_476884/ (date of access: 25.01.2025).
10. Criminal Code of the Russian Federation dated 13.06.1996 No. 63-FZ. URL: https://normativ.kontur.ru/document?moduleId=1&documentId=489053/ (date of access: 25.01.2025).
Review
For citations:
Svetkina I.A., Sakhchinskaya N.S. Tax security in case of risks of business fragmentation by retail entities. Vestnik of Samara State University of Economics. 2025;(4):121–130. (In Russ.)
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