RE: News on Pavel4 Feb 2021 17:35
Part 3
However, the main block of requirements of the Federal Tax Service was built on the interaction of Yuzhuralzolot with foreign companies. After a detailed study of the operation of the asset of Konstantin Strukov with the involvement of the FAS, the competent authorities of several countries and the Interpol branch, the auditors came to the conclusion that a scheme had been built with the inclusion of nominal, controlled companies from Cyprus in the cash flow chain to obtain the right to preferential taxation. In reality, the funds, as indicated by the fiscal authorities, went in transit to other legal entities.
Based on this, the inspectors indicated that when paying income to Ugold Limited (Cyprus) UGK had to fulfill the duties of a tax agent and withhold tax at a rate of 15%, not 5%, and in the case of transfers from Meldexx Leasing Mining Ltd (Cyprus ) apply a 20% withholding rate, rather than exempt this income from taxation.
With both companies, as follows from the materials of the court proceedings, Yuzhuralzolot signed loan agreements, and the Chelyabinsk asset paid multimillion-dollar interest on them.
At the same time, the fiscals pointed to the connections between the participants in the chain. “Former directors and committees of Ugold Limited: Roman Vladimirovich Berger - director from 12.09.2011 to 05.09.2012, Larisa Vladimirovna Ivleva - director from 12.09.2011 to 05.09.2012, Konstantin Ivanovich Strukov - director from 12.09.2011 to 05.09.2012. The shareholders of Ugold Limited from the moment of its establishment were: Ugold Foundation (Liechtenstein), Konstantin Ivanovich Strukov, Vladimir Dovzhenko, Alexey Kuznetsov, Evgenia Kuznetsova, Alexandra Strukova, Lyudmila Strukova - in the period from 04.09.2007 to 12.07.2013. In the period from 12.07.2013 to 06.02.2017, 100% of the shares belonged to Ugold Pic (Channel Islands). Since 02/06/2017, 100% is controlled by the company Ugold Holding LTD (Virgin Islands) ", - indicated in the materials of the tax audit.