Energy Group filed a claim to the State Tax Inspection in Svyatoshyn district of the Main Department of State Fiscal Service in Kyiv on cancellation of tax notice-decisions which estimated the CPT liabilities in the total amount of UAH 2 968 556,25 and reduced the negative value of CPT in the total amount of UAH 1 694 876,00.
The Higher Administrative Court supported the position of lawyers ILC «EUCON» with respect to the unreasonable conclusions drawn by the tax authority to the taxpayer on the occurrence of non-repayable financial aid in bill transactions, and occurrence of payments in international sales contracts and in transactions with repayable financial aid.
The Court of Cassation confirmed the conclusions that the running of the statute of limitations begins on the day following the last day on which the relevant obligation shall be fulfilled. And if deadlines for fulfilling such obligations are extended by parties of the contract, then the limitation period shall be calculated from the extended term of fulfillment of obligations.
Attorney, deputy head of litigation department of the ILC «EUCON» Volodymyr Bevza, led by managing partner, attorney Yaroslav Romanchuk supported a case before the court.