The spin-off of a legal entity automatically triggers the risk of a tax audit.

The State Tax Service has confirmed that the spin-off of a legal entity from a parent company constitutes grounds for a documentary unscheduled audit. Despite the fact that, from a civil law perspective, a spin-off does not entail the termination of a legal entity, for tax purposes it is treated as a form of reorganization.

The tax authorities emphasize that a spin-off is explicitly classified as a reorganization process and therefore automatically falls under the grounds for audits. This means that the very fact of corporate restructuring may trigger tax scrutiny regardless of whether any violations exist. Accordingly, taxpayers should take such risks into account in advance when planning transformations.