19 августа 2019
Екатерина Уцына
AndreyPopov / Depositphotos.com
ФНС России рассказала о подходе к оценке возможности получения холдинговой компанией самостоятельных доходов от российских источников (письмо ФНС России от 8 августа 2019 г. № ЕД-4-13/15696@). Разъяснения даны для выработки единообразных подходов при формировании доказательственной базы в рамках мероприятий налогового контроля о неправомерном применении налогоплательщиками и налоговыми агентами преференций по международным соглашениям об избежании двойного налогообложения.
Налоговые инспекции при проведении проверок организаций делали вывод об отсутствии у компании самостоятельной предпринимательской деятельности только на содержащихся в корпоративных документах упоминаниях о ее холдинговом характере деятельности. ФНС России полагает такой подход к раскрытию концепции фактического права на доход (бенефициарного собственника) формальным.
Сама по себе деятельность по инвестированию и финансированию компаний группы или взаимозависимых, аффилированных лиц не свидетельствует об отсутствии коммерческой деятельности. Ведь холдинговые компании специализируются на владении и управлении принадлежащими им пакетами акций. Между тем, это могут быть как внутригрупповые промежуточные холдинговые компании, которым, как правило, принадлежит 100% дочерних операционных предприятий международной группы компаний, так и инвестиционные холдинговые компании (портфельные холдинговые компании), которые держат диверсифицированные пакеты ценных бумаг для одного или нескольких инвесторов.
Поэтому, как указывает налоговая служба, в каждом конкретном случае в рамках контрольных мероприятий необходимо проводить анализ на наличие признаков искусственности в деятельности холдинговой компании, в том числе признаков отсутствия самостоятельности в части принимаемых решений по отношению к принадлежащему компании активу и в отношении рассматриваемого дохода от российского источника.
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