The Federal Tax Service blocked the accounts of 8 of MGCL's 11 subsidiaries for a total of 1.22 billion rubles, four of which filed bankruptcy cases - the parent company's shares fell 17.5% as of October 26. If the tax claims against subsidiaries reflect systemic problems with transfer pricing within the group, what mechanism would allow FTS to reach the balance sheet of the parent company? Oleg Abelev, Head of the Analytical Department of the Rivcom-Amon Investment Company: The main mechanism is the recovery of dependents under Article 45 of the Tax Code. But it requires proof that the parent company benefits from the transfer of the subsidiary's property, because such a transfer is for tax reduction. In fact, this is the only legal way for the Federal Tax Service to hold legal entities responsible and collect tax debts with the parent company. But this rule must be applied very carefully. First, the debt must arise as a result of a tax audit. It should be established as a result of an on-site inspection and expires more than three months. Second, the importance of interdependence must be recognized. That is, the court must recognize the parties as dependent persons. Although MGCL and its subsidiaries are such in nature, the FTS must prove that their actions were intended and intended to attack tax. Third, the transfer of property must be established. That is, the Federal Tax Service must prove that the subsidiaries transferred money, property or property rights to the parents. Most importantly, the purpose of the transfer is eva no. That is, the transfer, in theory, should have occurred after the governments learned about the beginning of the tax audit and not before. Because then it turns out that the goal is different.