VAT Refund Court Practice Development Without Sales Realization in Russia

• Russian court ruled in favor of Atomsnab company regarding VAT refund claims for road construction on leased land without outgoing VAT transactions
• Tax inspection denied VAT refund based on unfinished road condition and lack of evidence for VAT taxable activity use
• Court determined that VAT deduction applies to operations aimed at future sales activities even when no actual sales occurred in the reporting period
• Three party contract with Wildberries confirmed the company used disputed road construction for business purposes regardless of land ownership status
• Court emphasized VAT deduction criteria require intention to use acquired goods or services for VAT taxable activities rather than completed results or concurrent taxable operations

Source: russiantaxandcustoms.com

Note that this post was (partially) written with the help of AI. It is always useful to review the original source material, and where needed to obtain (local) advice from a specialist.

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