The business associated with the family of the fugitive ex-governor of the Chelyabinsk region Mikhail Yurevich, who is accused of receiving multibillion-dollar bribes, must pay large sums to the budget. Such conclusions were reached by the court of first instance following the dispute between the Rodnik company and the Federal Tax Service Inspectorate for the Sovetsky District of Chelyabinsk. In particular, the company, whose activities are associated with the largest shopping malls in the South Urals “Rodnik” and “Almaz”, was presented with an underestimation of the corporate income tax base by hundreds of millions. According to the conclusions of the auditors, it happened after the reorganization of Makfa, the merger of companies and the reduction of the authorized capital of Rodnik. Fiscals also pointed to the “carousel” cash flow in the group with the participation of the foreign company Rantip Invest Limited, which cost the budget tens of millions. According to the auditors, the funds remained in the contour of the business through a series of payments and loans, and the expenses of Rodnik were artificially increased. Similar schemes have already been recorded in disputes between the state agency and businesses related to the ex-governor’s family, and according to observers, apparently, “they were a common practice of scrolling money in this group.”
LLC “Rodnik” was unable to challenge the multimillion-dollar claims of the Federal Tax Service Inspectorate for the Sovetsky District of Chelyabinsk. The company insisted on invalidating the decision of the fiscal authorities regarding the additional charge of corporate income tax in the amount of 98.8 million, penalties for 48.1 million, a fine, as well as reducing the loss for 2018 in the amount of 203.9 million rubles.
The conflict was built on three episodes. The first is the definition of depreciation groups for fixed assets. According to the results of the audit, fiscal officials came to the conclusion that the company unreasonably overestimated depreciation charges.
The second episode is the reduction of the authorized capital. Analyzing it, representatives of the Federal Tax Service pointed to an underestimation of the corporate income tax base by 212 million for 2017, which occurred as a result of non-inclusion in non-operating income of the amount of reduction in the authorized capital. The result, according to auditors, was the non-payment of tax on 42.4 million rubles.
In this case, the fiscals began to argue their claims with an extraordinary general meeting of shareholders of Makfa OJSC, at which a decision was made to reorganize the company in the form of spinning off Melon LLC from it. The authorized capital of the newly created LLC then amounted to 280 thousand rubles. At the same time, assets in the amount of 266.9 million rubles were transferred to Melon, including a share in the authorized capital of Rodnik LLC in the amount of 212 million rubles.
“According to the information of the Unified State Register of Legal Entities, the participants of Melon as of the date of its registration (04/04/2017) are: Yurevich Valery Mikhailovich, a share of 71.43%; Yurevich Natalya Evgenievna, share 16.17%; Belousova Irina Borisovna, share 9.29%. From July 19, 2017, Trescode Limited (TRESCODE LIMITED, Cyprus) becomes the main participant in Melon with a share of participation of 76.05%, and from September 1, 2017 – with a share of participation of 91.7%. <…> The participant of TRESCODE LIMITED (Cyprus) is Yurevich AM (grandson of V. M. Yurevich and N. E. Yurevich). submitted to the court.
Further, as fiscal officials note, Melon LLC is already joining Rodnik LLC. The owner of the latter becomes a foreign company – TRESCODE LIMITED, and the authorized capital is fixed in the amount of 280 thousand rubles.
“Thus, taking into account the voluntary reduction <...> income in the form of the amount by which the authorized capital was reduced <...> in the amount of 212 million rubles, was subject to accounting when determining the tax base <...> as part of non-operating income <...> Based on the above the court considers the disputed decision in this part to be lawful, and the society’s demands not to be satisfied, ”the arbitration concluded as a result.
The court agreed with the arguments of the fiscals and on the third episode, concerning the calculation of interest on loans received from Rantip Invest Limited and Chigintseva Valeria Vadimovna. As a result of this scheme, according to the Federal Tax Service, incomplete payment of income tax in the amount of 45.7 million rubles was allowed.
“From the circumstances established by the audit, it follows that within the group of related companies (Makfa JSC, First Khlebokombinat JSC, Rantip Invest Limited, Rodnik, Chigintseva V.V., Belousova I.B.) a “carousel” was organized cash flow aimed at reducing the tax liabilities of one of the participants – “Rodnik” – follows from the position of the auditors.
Speaking about the circular movement of money, representatives of the Federal Tax Service emphasized that in fact the funds were not removed from the possession of one group, and the deal to obtain a loan from a foreign company was aimed at increasing the expenses of Rodnik. “When analyzing the settlement accounts of these organizations, it was found that Makfa and Perviy Khlebokombinat transferred dividends to Rantip Invest Limited. Through the received dividends, Rantip Invest Limited issued a loan in the amount of 72.5 million euros to an audited taxpayer at 4% per annum, which, in turn, closed its debt obligations to Makfa and Pervy Khlebokombinat using the received loan. The First Khlebokombinat transfers the funds received from Rodnik in the form of dividends to Rantip Invest Limited,” the tax authorities noted.
To clarify, Pravda UrFO has already described similar schemes, as a result of which large sums were additionally charged to Makfe. In addition, Rantip Invest Limited, which fiscals consider a conduit organization, has also been involved in other major disputes with the Federal Tax Service.
It should be noted that now, according to the data of the Kontur.Fokus system, the owners of the authorized capital of Rodnik LLC are ZACOSTAL LTD (Zakostal LTD; Cyprus) with a share of 90.7% and SULA GRANTI LTD (Sula Granti LTD; Cyprus) from 9.3%. Market participants associate the company with the family of the fugitive ex-governor of the Chelyabinsk region Mikhail Yurevich.
Thus, according to the system, Rodnik is headed by Elina Shumakova, who is also listed as the director of Shkolnik Universal Store LLC and appeared as the head of the New Planet LLC organization. The participants of the latter, according to “Kontur.Focus”, are Yurevich Alexander Mikhailovich (90%) and the aforementioned “Sula Granti LTD”. Shumakova was also the head of Melon LLC, which was spun off from Makfa.
We add that Rodnik LLC, Otelstroy LLC, UM Shkolnik LLC were also mentioned in other business disputes between the family of the ex-governor of the Chelyabinsk Region Mikhail Yurevich and the Federal Tax Service. “Rodnik” is connected with the largest shopping malls in the Chelyabinsk region “Rodnik” and “Almaz”.
