What objective criteria will the tax authority guide itself by to establish the fact of business splitting?
From January 1, 2026, amendments to the Tax Code came into force, aimed at preventing schemes related to the distortion of information on financial and economic activities, artificial business splitting, and obtaining unjustified tax benefits, as well as ensuring the principle of fair competition.
In this regard, Article 30 of the Tax Code "The Principle of Good Faith of the Taxpayer (Tax Agent)" has been supplemented with a provision prohibiting actions aimed at distorting information on the facts of financial and economic activities, or splitting a business in order to obtain a tax benefit (tax savings) and reduce tax payments.