Sizova, A. M. Tax Consequences of the Reorganization and Liquidation of Participants of a Consolidated Group of Taxpayers

Abstract: Implementation of the consolidated taxation system has been a necessary step towards development of the Russian taxation system. However, since it is a completely new system, it creates a challenge for both tax authorities and taxpayers. Being, in fact, a special tax regime for holding companies, the consolidated taxation system must take into account peculiarities of holdings, in particular, often reorganization and liquidation of enterprises. The article deals with the tax consequences of these processes for participants of consolidated group of taxpayers, in particular, problems related to follow-up field tax inspections. The author of the article in detail analyses the legislative and regulatory framework of reorganization and liquidation of consolidated groups of taxpayers. Special attention is paid to effective provisions of the Tax Code of the Russian Federation and explanations of the Ministry of Finances and Federal Tax Service of Russia. Based on the results of the performed analysis the author offers to make changes to the provisions of the Tax Code of the Russian Federation concerning the grounds for conducting a field inspection after reorganization or liquidation of an enterprise. According to the author, adequate changes would clarify uncertainties in tax legislation and eliminate the risk of possible disputes between tax authorities and taxpayers who have created a consolidated group of taxpayers.

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