Business fragmentation: formation of criteria, building a line of defense on the part of taxpayers

The article discusses one of the most common types of tax disputes - business splitting. The relevance of the topic is due to the fact that at the legislative level there are no restrictions on the choice of a business model by a taxpayer, while law enforcement practice has developed criteria that together may indicate dishonest behavior of a taxpayer. The main criteria for recognizing the splitting of a business as illegal are analyzed. The analysis of judicial practice carried out by the authors makes it possible to systematize the grounds for protection in case of splitting and form a strategy for protection against additional charges when building a business that has a practical business purpose.