Annotation

This article analyzes one of the most complex phenomena in Russian tax law: business fragmentation. It examines the lack of a legislative definition of this concept and analyzes the legal positions of the Supreme Court of the Russian Federation and the Federal Tax Service. Special attention is given to the criteria for artificial business fragmentation and the mechanism of tax reconstruction. The authors identify the main grounds for holding taxpayers accountable and provide recommendations for distinguishing between legitimate business structuring and illegal tax evasion schemes.