27/08/2026
Analysis of interdependence and risks associated with business fragmentation
Our cases: https://valen-legal.com/cases/
Situation:
The client – a group of companies engaged in the equipment trade – contacted Valen Group as part of an analysis of its corporate structure.
The client’s task: to assess the tax risks of a group consisting of two limited liability companies and an individual entrepreneur, who operate in the same trade segment, and to determine whether the tax authority may consider their activities as a single business.
Valen Group’s specialists:
1. Analyzed corporate relationships, personnel, assets, suppliers and customers, intra group settlements, commodity flows, and the tax regimes applied.
2. Identified a set of indicators of interdependence — a common address and contacts, personnel, infrastructure and assets, common suppliers and customers, significant intra group transactions, and interest free financing. The likelihood of recognizing the parties as interdependent is assessed as high.
3. Divided the risks in detail for each party and period. The identified potential consequences of reclassifying the activities could amount to approximately 100 000 000 Rubles.
4. Developed a set of measures to reduce risks — settling intra group debts, delineating functions and resources, changing the structure of interaction between participants, selecting the optimal model for product distribution and tax regime, as well as documentally formalizing the business’s independence.
The result for the client: we did not just identify the risk of fragmentation but developed a practical model for the group’s further operation, taking into account the tax burden and the position of the tax authority.
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