A demand ignored is a demand granted
Response windows on FTS acts are short. Default is how additional assessments become enforceable. A parent that “will look at it next quarter” has already lost the cheapest stage of the fight.
- Desk-audit additional assessments that go final without objections
- Field audits that expand into related-party and VAT chains
- Penalties and interest that outrun the underlying tax
- No English-language record of what was argued
What it is
A desk audit is a letter. A field audit is people in the archive. Both can reopen three prior years and convert a dormant subsidiary into a seven-figure ruble assessment plus penalties. The foreign parent cannot appear, cannot easily collect the paper, and cannot read the clock on a Russian-language demand.
Colibry organizes in-country representation: objections, document packs, appearance at the review of materials, appeal to the regional FTS, and a litigation file if the dispute is referred to arbitration court. Every stage is translated into an English decision note for GC and, where you ask, for U.S. sanctions counsel.
What is in scope — and what is not
We do
- Initial review of the demand or audit report, with a written risk assessment in English
- Objections to desk and field audit reports, in Russian form
- Document collection, numbering, and production to the tax authority
- Appearance at the FTS review of audit materials
- Pre-litigation appeal to the regional FTS; talks on restructuring where they exist
- A legal position pack for arbitration court if the case is referred (court appearance with local counsel as needed)
- English updates at every procedural stage, with dates and what we recommend you decide
We do not
- A guarantee of a zero assessment
- U.S. litigation or OFAC administrative proceedings
- Criminal-tax defense (we will tell you immediately if the file has crossed that line)
How the work runs
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01
Triage
48-hour read of the act: amount, years, theory, deadline.
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02
File
What exists in 1C, contracts, and prior returns. What must be reconstructed.
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03
Object
Written objections and, if opened, the field-audit protocol.
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04
Appeal or settle
Regional FTS, then court pack if the numbers still justify it.
Calendar
| When | What |
|---|---|
| Day 0–2 | Triage note to the client |
| Statutory window | Objections — we work backward from the FTS clock, not from yours |
| Thereafter | Review, appeal, court — months to two years |
What we need to start
Missing items are a workstream, not a reason to wait. A signed note that a year of filings does not exist is more useful than another month of silence.
- The FTS act, demand, or field-audit decision (scans are enough to start)
- Returns and accounts for the years named
- Contracts, invoices, and bank for the theories in the act
- Prior objections or court filings, if any
Reporting
English note at each statutory gate: what the FTS said, what we filed, the next date, and the decision we need from you.
Who it is for
Entities that have received an FTS demand, an on-site audit notice, or an additional-assessment report.
We will not take
- A file that is already a criminal case without local criminal counsel
- Listed counterparties
Fees and start
Fixed-scope engagements with fees agreed in advance. Pricing is set after an initial consultation at no charge. Initial assessment: 1–2 weeks. Full mandate: 3 months to 2 years, depending on stage. See how the New York contract works and the week-one document pack.