Annotation

Tax amnesty for business splits has fundamental legal differences from other types of liability exemptions. The legislator did not limit himself to prohibiting the unfair use of special tax regimes, but also proposed a mechanism for transitioning from an unlawful model of behavior to a legal one. The legal consequences are determined not only by the previous violation but also by the taxpayer's behavior in subsequent financial periods. The following objectives of tax amnesty for business splits are identified: fiscal, legalization, preventive, and institutional. The issue of taxpayer equality in terms of participation in the amnesty procedure is examined. Individuals who initially complied with tax laws do not receive preferential treatment as a result of the amnesty. With regard to the amnesty for business fragmentation, the inequality of legal status between bona fide and evading taxpayers is partially offset by its one-time nature, limited financial periods, and dependence on subsequent oversight. It is argued that the success of the amnesty, as well as the overall level of trust among business entities in modern tax administration, depends on how consistently the criteria of independence, business purpose, and proper tax reconstruction are applied.