Support client in the field tax audit


INFRALEX has provided legal and tax advice to the subsidiary of a holding company specializing in rail transportation of oil and oil products in Russia, Ukraine, Kazakhstan and some EU countries. The tax audit conducted by the Russian tax authorities in relation to the company covered, in particular, the relationships between the company and its key suppliers, whose services were indispensable.

Actions taken

The features of the client’s activities related to the legal regulation of railway transport have made the legal analysis of the situation and the provision of effective protection measures for the company a truly difficult matter. In addition, payments made by the company to its shareholders felt under the control of the tax authorities and that created serious tax risks.

During the tax audit, our lawyers prepared an argumentation for the client’s position on all issues considered by the tax authorities. 

An explanation of the client’s necessary actions prepared by INFRALEX lawyers, as well as the representation of its interests during the tax audit, convinced the tax authorities in the legitimacy of the company’s actions in most disputed situations.


Tax audit results fully met the customer's expectations, as most of the tax authority claims were found unjustified. In this regard, the client considered the contestation of the tax audit act inappropriate.