Andsource Billions from the sale of rubble shared. Producers spend years fighting the fiscal authorities. The Federal Tax Service again caught the companies of the Ural businessman Sergei Mazurkevich on non-payment of taxes. However, firms are actively challenging the demands of the fiscals in the courts. Earlier, the Federal Tax Service described in detail the scheme for reducing the MET, implemented by a group of legal entities associated with the entrepreneur. Dolomite mining companies at extremely low prices sold raw materials for enrichment to two firms, and the latter sold it to a trading house that already had billions in revenue. In fact, as the fiscals found out, the enrichment of ores was not carried out, and the products were sold as crushed stone. During the proceedings, some of the “ore enrichment” firms stopped working and were liquidated. At the same time, new legal entities for the extraction and sale of crushed stone have appeared, the activities of which are actively interested in the Federal Tax Service. Representatives of the legal community believe that the scheme for avoiding the MET can be implemented again, and do not exclude various options for saving on personal income tax. At the same time, companies associated with the businessman occupy a significant share in the Urals market, and prices and demand for crushed stone in the region continued to grow rapidly during 2022.
The Arbitration Court of the Sverdlovsk Region refused Konovalovsky Rudnik LLC (according to Kontur.Focus, the owner of 100% of the authorized capital Sergey Mazurkevich) to cancel the decision of the Federal Tax Service to charge additional mineral extraction tax and penalties for a total amount of about 8 million rubles. The company pointed to the expiration of the limitation period for the recovery of funds, as well as mathematical errors in calculating the fine of 11 thousand rubles. However, the court did not find confirmation of the arguments. At the same time, he pointed to the collection of debts for the MET from OOO Uraldolomit, with which the company is part of a group of legal entities that implemented a scheme to evade the payment of the MET.
During 2022, Uraldolomite is trying to challenge in the arbitration court the recovery of a debt on the mineral extraction tax of 26 million rubles accumulated from 2015 to 2017, a penalty on it of 10 million, as well as a debt and interest on income tax of 650 thousand rubles. rubles. He managed to cancel only the last demands of hundreds of thousands. As follows from the materials of the case, Uraldolomite sold the rock mined near Bilimbay to LLC Stone Crushing Plant and LLC Uralsky Rudnik for 26 rubles per ton. Enterprises crushed it into crushed stone and screenings on equipment rented from the seller, did not produce dolomite enrichment and sold the products of Uraldolomite Trading House LLC at a price of 179 to 450 rubles per ton. Thus, they sold more than 720 thousand tons. In turn, the trading house sold products at times more expensive.
All of these legal entities, as established by the FTS specialists, are interconnected, and “the interests of a group of interdependent persons are represented by employees of Transsibural LLC (founder and head Mazurkevich S.L.)”.
Since 2016, the “Stone Crushing Plant” has not actually conducted any activity. According to the arbitration, the employees were transferred to the Uralsky mine, which stopped a year later, and then to the Konovalovsky mine, which continues to work at the present time. By the way, the revenue of the latter from 2017 to 2019 increased almost 3 times – from 35 to 90 million rubles, and by the end of 2021 fell to 61 million rubles. However, employees were not officially employed in the company last year, and a year earlier their number was limited to a few. the company increased its revenue from 218 to 790 million rubles in 5 years. The trading house of the same name at the same time showed revenue of 8.6 billion rubles.
In 2019, the Uraldolomite Trading House is also creating a new Uralsky Shcheben LLC for mining at a field near Severouralsk with an authorized capital of 187 million rubles and more than 200 employees. However, this company will soon face the claims of the fiscals. According to the results of the audit, only for 3 months of 2020, she was charged an additional severance tax of 7.8 million rubles. But the company considered the actions of the tax authorities unlawful and tried to challenge in arbitration. By August 2021, the amount of debt had grown to 13.6 million rubles, but the company continued to challenge the decisions and ultimately lost in court. It was only a bankruptcy lawsuit that prompted the company to pay tax debts, which have grown to 39 million this year.
At the same time, Sergei Mazurkevich's companies had funds to pay off tax debts before. For 3 years, Uralsky Shcheben increased its revenue from 214 to 561 million rubles, but showed a very modest net profit of 3-5 million rubles. In its turn, Trade House Uralsky Shcheben LLC increased its revenue for the same period by 2 times – up to 1.2 billion rubles (net profit amounted to 65 million rubles).
“The described scheme for avoiding the MET is widely used by this entrepreneur and, with a high degree of probability, will continue to be practiced further. Mining licenses are issued for some enterprises, equipment under lease agreements plus 1% is provided to other legal entities, the final product is sold by trading houses. In reality, the entire product can be extracted from one or two deposits and sent from there directly to the final recipients. In addition, attempts are probably being made to save on personal income tax, since the personnel of the Konovalovsky Mine can be recruited under civil law contracts or from a third-party legal entity. It is possible to implement such schemes only if we have a large staff of lawyers and accountants,” a representative of the legal community who is familiar with the activities of Mazurkevich’s companies describes the situation. Its annual production, according to the website of the Ural Mining Holding, is 3.5 million tons. “Uralsky rubble” reports the possibility of mining up to 1.8 million tons per year. For comparison, the largest volumes of crushed stone production are more than 12 million tons from Uralasbest PJSC. In 2022, prices for crushed stone in the whole of the Russian Federation increased by more than 25%, which is largely due to the intensification of road construction, including the M12 Moscow-Kazan-Yekaterinburg highway.
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