Triple reduction in tax assessments and a cancelled tax notice – a big win for our agribusiness client

22/ 10/ 2025

KM Partners team has secured an important victory for an international agricultural company in a dispute with the tax authorities over the use of quoted prices in assessing compliance with the arm’s length principle. The State Tax Service inspected the client’s export transactions for 2015–2019 and insisted on using quoted prices from the recommended list published by the tax authorities, disregarding alternative sources relied upon by the client. We challenged these findings and, as a result: the additional tax assessments were reduced threefold at the stage of objections; the tax notice-decision was fully cancelled following the review of the complaint. This decision is particularly significant, as it highlighted the unlawful practice of applying quoted prices to periods prior to 2021. While a follow-up tax audit is anticipated, this case already sets a positive precedent for taxpayers.

KM Partners’ team has secured an important victory for an international agricultural company in a dispute with the tax authorities over the use of quoted prices in assessing compliance with the arm’s length principle.

The State Tax Service inspected the client’s export transactions for 2015–2019 and insisted on using quoted prices from the recommended list published by the tax authorities, disregarding alternative sources relied upon by the client. We challenged these findings and, as a result:

the additional tax assessments were reduced threefold at the stage of objections;
the tax notice-decision was fully cancelled following the review of the complaint.

This decision is particularly significant, as it highlighted the unlawful practice of applying quoted prices to periods prior to 2021. While a follow-up tax audit is anticipated, this case already sets a positive precedent for taxpayers.