Sponsorship Agreements and Advertising in Russia: A Comprehensive Legal and Tax Guide

 

January 24, 2025

Anna Ivanova, Associate at BRACE Law Firm ©

 

Currently, many companies provide sponsorship and/or co-financing for conferences, symposia, forums, seminars, and other events. Such events, among other things, aim directly at advertising and promoting the advertiser's brand or products.

For example, in the healthcare sector, pharmaceutical companies and medical device manufacturers frequently organize scientific conferences, webinars, forums, and other events for the professional community of physicians and/or pharmacists. These often involve medical and/or pharmaceutical workers, including guest expert lecturers. Pharmaceutical companies, medical device manufacturers, and other healthcare and medical technology businesses often finance such events, in whole or in part, through sponsorship.

In practice, a significant number of questions and problems arise, including the legal nature of sponsorship agreements and their differences from charity, the compliance of sponsorship advertising with legal requirements, sponsorship taxation, and others that require detailed consideration.

What is Sponsorship and Sponsorship Advertising?

Current legislation provides no definition for the term "sponsorship". However, the previously effective Federal Law No. 108-FZ dated July 18, 1995, On Advertising established that sponsorship means the contribution made by a legal entity or individual (the "Sponsor") (in the form of providing property, results of intellectual activity, rendering services, or performing work) to the activity of another legal entity or individual (the "Sponsored Party") on the condition that the Sponsored Party distributes advertising about the Sponsor and its products. Based on this law, judicial practice was formed where a sponsorship contribution is recognized as payment for advertising, and the Sponsor and the Sponsored Party are recognized as the advertiser and the advertising distributor, respectively. [1]

Following the repeal of Federal Law No. 108-FZ dated July 18, 1995, On Advertising and the adoption of the new Federal Law No. 38-FZ dated March 13, 2006, On Advertising (the "Law on Advertising"), which contains no definition of "sponsorship", judicial practice has interpreted sponsorship as a paid advertising service consisting of the recipient of sponsorship aid mentioning information about the Sponsor (Clause 3 of the Resolution of the Plenum of the Supreme Arbitration Court of the Russian Federation No. 58 dated October 8, 2012, On Certain Issues of the Practice of Application by Arbitration Courts of the Federal Law On Advertising).

In academic literature, sponsorship is understood as material support for someone or something to create or maintain a positive reputation or gain publicity. Experts believe that sponsorship is inherently driven by a pursuit of benefit and advertising. [2]

Article 3 of the current Law on Advertising defines the terms Sponsor and Sponsorship Advertising. A Sponsor is a person who has provided funds or ensured the provision of funds for the organization and/or holding of a sporting, cultural, or any other event, the creation and/or broadcast of a television or radio program, or the creation and/or use of another result of creative activity. Sponsorship Advertising is advertising distributed on the condition of mandatory mention of a specific person as the Sponsor therein.

Despite the current lack of a legislative definition for "sponsorship", the definitions provided above reflect the characteristics of modern sponsorship and sponsorship advertising.

Specifically, several experts note that legislation implies the provision of sponsorship aid with mandatory reciprocal obligations (mentioning the Sponsor), meaning it is not provided gratuitously. [3]

In some cases, courts apply the provisions of the Civil Code of the Russian Federation (Civil Code) regarding the paid rendering of services to sponsorship agreements. For instance, in one ruling, the court concluded that: "current legislation does not define the concept of a sponsorship aid agreement; therefore, the court is guided by the terms set forth in the agreement itself. Furthermore, legislation contains no prohibitions on establishing reciprocal obligations in relation to the provided sponsorship aid; thus, the provisions of Article 328 of the Civil Code of the Russian Federation regarding the reciprocal performance of obligations apply to the parties' obligations." [4]

Essentially, the general provisions on obligations and contracts apply to the agreement concluded between the Sponsor and the advertising distributor. For example, one court ruling established that misrepresenting the Sponsor's name should be viewed as improper performance of obligations by the advertising distributor and should entail relevant civil law consequences. [5]

Thus, the legal nature of sponsorship consists of the Sponsor providing aid for an event in exchange for the Sponsored Party's reciprocal provision of an advertising service by mentioning the Sponsor.

What are the Differences Between Sponsorship and Charity?

The presence of a reciprocal obligation to mention the Sponsor is the primary factor in distinguishing sponsorship from charity. This is because charitable activity is defined as voluntary activity by citizens and legal entities for the disinterested (gratuitous or on preferential terms) transfer to citizens or legal entities of property, including funds, the disinterested performance of work, the rendering of services, or the provision of other support.[6] Thus, charitable aid is provided gratuitously (or on preferential terms), whereas sponsorship aid is typically provided in exchange for placing information about the Sponsor. Consequently, a sponsorship agreement is qualified as a transaction for consideration. Charity may also involve consideration, as the law uses the phrase "on preferential terms." However, the element of consideration is not fundamental to charity, unlike sponsorship.

It is important to note that legislation does not prohibit recipients of charitable aid from mentioning the benefactor, and the benefactor may report its charitable activities on its own website or other resources. However, such a condition is optional in charity, whereas it is fundamental in sponsorship.

This assertion is supported by judicial practice, where a court rejected arguments to reclassify sponsorship agreements as gift agreements. The court noted that "current legislation of the Russian Federation lacks a definition for a sponsorship contract; therefore, its legal qualification depends on the nature of the obligations expressed therein and the actual intent of the parties." The ruling was based on the fact that a sponsorship contribution has a specific purpose and implies reciprocal obligations. If a Sponsor must finance a certain event, the other party to the agreement must, in turn, distribute information about the Sponsor, its goods, and services. A sponsorship contribution is recognized as payment for advertising, and the Sponsor and Sponsored Party are recognized as the advertiser and advertising distributor, respectively. However, in the dispute under consideration, the sponsorship aid agreements, certificates of work performed, and reports on work results confirmed the existence of sponsorship contractual relations within the amount of the disputed transfers and the existence of performed obligations between the parties. [7]

Consequently, sponsorship aid may imply consideration from the Sponsored Party in the form of distributing information about the Sponsor, as the Sponsor provides aid in exchange for the distribution of information about itself. This, in turn, is recognized as advertising. [8] However, unlike conventional advertising, sponsorship aid has several characteristics, which we will consider in detail below.

What are the Requirements for Sponsorship Advertising?

Sponsorship advertising is a type of advertising and is subject to both the general requirements imposed by the Law on Advertising and the special requirements established by said Law on Advertising. [9]

Specifically, Article 5 of the Law on Advertising establishes general requirements for any advertising, such as requirements for integrity and accuracy, and prohibitions on calls for violence, the commission of illegal acts, the demonstration of illegal acts, and others.

Furthermore, Part 3 of Article 14 of the Law on Advertising stipulates that the total duration of advertising distributed in a television program, the interruption of a television program by advertising (including sponsorship advertising), and the combination of advertising with a television program by "crawling text" or any other method of overlaying it on the television frame may not exceed 15% of the broadcasting time per hour.

At the same time, Parts 3.4 and 3.5 of Article 14 of the Law on Advertising increase this permissible advertising volume for regional television channels. Such channels may increase the total advertising volume by combining advertising with a television program via "crawling text" — but not by more than 5% of the broadcasting time per hour beyond the total advertising duration (meaning the advertising volume may be increased to 20% of the broadcasting time per hour). [10]

When conducting sponsorship advertising, questions may arise regarding the calculation of these 15–20% limits. On this issue, FAS Russia clarifies that "...if two or more television channels are broadcast on one frequency under relevant licenses, the advertising volume in such mass media is calculated for each medium based on its daily broadcasting time. At the same time, the volume of advertising broadcast in a television program includes any advertising distributed during the broadcast of that program.

For example, regional advertising placed by a regional partner in a federal mass medium (under a relevant agreement between them) is included in the advertising volume of the federal mass medium. Conversely, advertising placed by a regional partner in a federal television program is not included in the advertising volume broadcast by that regional partner in the regional mass medium." [11]

In addition to the general advertising requirements mentioned above, an important distinguishing feature of sponsorship advertising, as clarified by FAS Russia, is that:

• only a person, and not a product, may act as a Sponsor;
• this person must be identified in the advertising specifically as a Sponsor.

An advertiser may indicate itself as a Sponsor in any form that designates its participation in the sponsored event.

However, if an advertisement indicates that a specific product or trademark is the Sponsor, such advertising will not fall under the definition of sponsorship advertising. [12]

For example, FAS Russia reviewed a case regarding the illegality of advertising distributed on invitation tickets for the Silver Galosh award ceremony, which contained information not only about the advertiser but also specifically about alcoholic products. It was established that such advertising, due to the mention of a product brand, cannot be sponsorship. Notably, the advertising distributor in this dispute argued that information about the ceremony sponsors and alcoholic products, distributed during the ceremony and on invitation tickets, was not advertising because it was addressed to persons specifically invited to the ceremony. Therefore, the "indefinite circle of persons" required for advertising was absent. However, these arguments were rejected by the control authority as follows: "Under the legislative definition of advertising, advertising must be intended for an indefinite circle of persons, meaning persons who cannot be predetermined as a specific party to the legal relationship arising from the sale of the advertised object. In this regard, the determinacy of the circle of addressees themselves is irrelevant." [13]

It is important to note that in addition to the general and special requirements for sponsorship advertising conducted within relevant events (sporting, cultural, scientific, etc.), additional requirements may apply. Specifically, if separate goods, works, or services are advertised along with the Sponsor, it may be necessary to comply with special requirements of the Law on Advertising applicable to specific categories of goods.

For example, current legislation does not prohibit the advertising of medicines during scientific events. Moreover, prescription medicinal products may be advertised specifically within such events. However, when conducting such advertising, the restrictions established by Article 24 of the Law on Advertising must be observed. Specifically, advertising materials for prescription medicines must not become accessible to an indefinite circle of persons or be distributed outside the event. For instance, in one case, FAS Russia established a violation after a brochure advertising a prescription medicine was found on a table in a patient waiting area of a city hospital. [14] In this regard, it is vital to control the potential subsequent distribution of the Sponsor's advertising materials outside the event by establishing the organizer's liability.

Judicial Disputes Regarding Participants in Sponsorship and Other Advertising

Another important aspect of organizing sponsorship advertising is potential disputes between the participants in the relevant contractual relationships.

For example, a court refused to invalidate parts of agreements for the installation and operation of advertising structures. The essence of the dispute was that a municipal contract led to an agreement granting the performer the right to install and operate advertising structures for theatrical posters exclusively to distribute advertising and information about theater repertoires, sporting, and other mass events, as well as information about event sponsors. However, the performer believed that restricting the use of the advertising structures violated the requirements of Federal Law No. 135-FZ dated July 26, 2006, On Protection of Competition, as the right to determine the types of advertised objects for specific addresses and structures is not legislatively established. Consequently, the structures should be usable for any type of advertising. The court held that the contract terms did not violate the law or third-party rights, as the municipality is entitled to determine the terms of agreements concluded via bidding. This case indirectly touches upon sponsorship advertising, as such disputes may lead to Sponsors (advertisers) being drawn into similar litigation. [15]

Another example of a judicial proceeding between parties to an agreement providing for sponsorship and Sponsor advertising is a case involving an agency agreement. The agent was obligated to attract sponsors for television programs; if the agent failed to attract sponsors and place sponsorship advertising, the agent was obligated to pay the principal for each program issue lacking sponsorship advertising. These terms were declared invalid. The court explained that "the obligations provided in the agreement contain elements of mandate, commission, and agency agreements. Since the attraction of sponsors is carried out by the agent on the principal's behalf and in the principal's interest, the terms of the contested clauses requiring payment to the principal for advertising that the agent did not place constitute a gift relationship and violate the reciprocal nature of the agreement provided by Article 1005 of the Civil Code of the Russian Federation." [16] As seen from the example above, this dispute did not directly involve the Sponsor. However, to guarantee a successful advertising campaign and event, it is recommended to verify the advertising distributor's reliability and the terms under which they organize the event, whether directly or through an agent.

Additionally, courts have noted that the financing of entertainment events where information about the financing party was placed does not mean the expenses for the events themselves can be considered advertising expenses. Consequently, the court supported the tax authority, which refused to recognize expenses for events not related to placing advertising. [17] It is important to note that this ruling is not recent; below, we will examine the specifics of sponsorship advertising taxation based on the latest enforcement practice and clarifications from the Ministry of Finance of the Russian Federation.

Thus, organizing sponsorship advertising often involves building complex contractual relationships and requires additional analysis to ensure compliance with all requirements established by the Law on Advertising. Special attention should also be paid to the characteristics of sponsorship advertising in healthcare and pharmaceuticals.

Sponsorship Advertising in Healthcare and Pharmaceuticals

The requirements for sponsorship advertising also depend on the Sponsor's business profile. The healthcare sector imposes significant characteristics due to special regulation.

For example, pharmaceutical companies must conduct a preliminary legal assessment of a planned event to ensure it does not violate the requirements of Article 74 of Federal Law No. 323-FZ dated November 21, 2011, On the Fundamentals of Health Protection of Citizens in the Russian Federation (the "Law on Health Protection"). According to this article, pharmaceutical and medical workers are prohibited from accepting gifts or funds from pharmaceutical companies and their representatives, including payments for entertainment, recreation, or travel to vacation spots, as well as participating in entertainment events held at the expense of said companies or representatives. Exceptions include remuneration under agreements for conducting clinical trials of medicinal products or clinical trials of medical devices, as well as remuneration related to the medical worker's pedagogical and/or scientific activities.

In practice, the question often arises whether a Sponsor's payment for physician training and/or participants' travel to an event venue constitutes a gift. The answer is not directly regulated by legislation, and no corresponding enforcement practice has been established. Consequently, one cannot rule out the risk of a sponsorship contribution being reclassified as a gift to a medical worker, despite being transferred through the event organizer (the advertising distributor).

It is also vital to monitor the form of sponsorship advertising, as Article 74 of the Law on Health Protection prohibits medical workers from receiving samples of medicinal products from pharmaceutical companies and their representatives for distribution to patients. Therefore, placing information about the Sponsor on medicine samples may lead to a situation where such materials and samples are transferred to patients, as controlling the further disposal of such samples by medical workers (outside the event) is quite difficult.

However, in our view, it is impractical to completely exclude the possibility of sponsoring scientific and other events for the medical community. The restrictions imposed on medical and/or pharmaceutical workers aim to limit abuses by pharmaceutical companies in promoting their products, rather than to restrict the exchange of professional experience.

To minimize such risks, it is essential to clearly specify the consideration terms for sponsorship and state that the recipient of sponsorship aid is responsible for organizing the event and interacting with the audience (including medical workers). The recipient must commit to complying with the requirements of the Law on Health Protection when holding the event (including the prohibition on giving gifts to medical workers, concluding agreements with them to prescribe specific medicines to patients, distributing medicine samples to patients, etc.).

Furthermore, as mentioned earlier, if a pharmaceutical company's sponsorship advertising includes the advertising of medicines, the materials must be checked for compliance with Article 24 of the Law on Advertising. For example, besides the violations mentioned regarding prescription drug advertising, a common violation involves guaranteeing the positive effect, safety, effectiveness, or absence of side effects of the advertised object. Specifically, it is prohibited to use words and expressions indicating a guaranteed result that allow no other interpretation (e.g., "eliminates pain", "will cure", "will defeat") [18], as well as images or video sequences showing recovery, such as the disappearance of inflammation upon using the advertised medicinal product. [19]

Additionally, under the general rule of Article 5 of the Law on Advertising, the use of images of medical and pharmaceutical workers is prohibited, except in advertising for medical services, personal hygiene products, advertising where the consumers are exclusively medical and pharmaceutical workers, advertising distributed at medical or pharmaceutical exhibitions, seminars, conferences, and similar events, and advertising placed in printed publications intended for medical and pharmaceutical workers. Consequently, one may preliminarily conclude that advertising materials about a Sponsor using a medical worker's image may be distributed at a pharmaceutical company's sponsored event for doctors. However, it is crucial to determine the composition of the event participants so that the materials are not distributed among persons who are not medical or pharmaceutical workers, and that the event itself qualifies as a medical or pharmaceutical event. If there is doubt regarding the event's focus or the audience's composition, it is recommended to refrain from using the image of a medical worker.

In light of the above, it is recommended to analyze the content of any advertising materials, including those mentioning Sponsor information (in sponsorship advertising), for compliance with the requirements of advertising legislation.

Taxes in Sponsorship and Sponsorship Advertising

According to Article 248 of the Tax Code of the Russian Federation (Tax Code), income for corporate profit tax purposes includes income from the sale of goods (work, services) and property rights, as well as non-operating income, as determined in accordance with Articles 249 and 250 of the Tax Code.

The sale of goods, work, or services by an organization or individual entrepreneur is defined as the transfer for consideration (including the exchange of goods, work, or services) of ownership rights to goods, the results of work performed by one person for another, or the paid rendering of services by one person to another. In cases provided by the Tax Code, this also includes gratuitous transfers or rendering (Clause 1 of Article 39 of the Tax Code).

The exhaustive list of income not taken into account when determining the corporate profit tax base is established by Article 251 of the Tax Code. Income in the form of a sponsorship contribution is not mentioned in this list.

However, in accordance with Sub-clause 28 of Clause 1 of Article 264 of the Tax Code, expenses for advertising goods, work, services, the taxpayer's activities, trademarks, or service marks are categorized as other expenses related to production and sale. Since sponsorship advertising is defined as advertising distributed on the condition of mandatory mention of a specific person as the Sponsor, sponsorship advertising will also be classified as sponsorship expenses. [20]

Consequently, according to clarifications from the Federal Tax Service of Russia, a sponsorship contribution received under a sponsorship advertising agreement is recognized as payment for advertising and, accordingly, is included in the corporate profit tax base of the sponsored organization as income from the rendering of services for a fee. [21]

When paying profit tax, for sponsorship expenses (sponsorship advertising expenses) to be accepted, they must be economically justified and documented.

There is no precise list of documents required to confirm the justification for accepting sponsorship agreement expenses as advertising expenses for profit tax purposes. In judicial practice, to prove the justification of sponsorship agreement expenses as advertising expenses, parties provide invoices, payment orders, certificates of services rendered, reports on the performance of obligations to distribute information about the Sponsor, photo and video materials, and other evidence. [22]

The issue of taxation when the Sponsor transfers property instead of funds deserves separate consideration. In such cases, it is recommended that the parties to the agreement draft a set-off agreement for reciprocal claims — specifically, offsetting advertising services against the property. The value of the transferred property must be fixed in the agreement and the set-off agreement. In this case, the property must be transferred via a transfer and acceptance certificate.

Furthermore, in addition to profit tax, sponsorship aid is included in the VAT tax base. [23]

Often, information about Sponsors may be contained in social advertising. In this case, the question arises whether the Sponsor's advertising will be subject to VAT.

Under Sub-clause 32 of Clause 3 of Article 149 of the Tax Code, the gratuitous rendering of services for the production and/or distribution of social advertising is not subject to (is exempt from) value-added tax.

Such operations are exempt from taxation provided that one of the following social advertising requirements is met:

• in social advertising distributed in radio programs, the duration of mentioning Sponsors does not exceed 3 seconds;
• in social advertising distributed in television programs or via cinema and video services, the duration of mentioning Sponsors does not exceed 3 seconds, and such mention occupies no more than 7% of the frame area;
• in social advertising distributed by other methods, the mention of Sponsors occupies no more than 5% of the advertising area (space).

As clarified by the Ministry of Finance of Russia, services for the distribution of social advertising rendered gratuitously are exempt from value-added tax. [24] However, social advertising may not mention specific brands (models, articles) of goods, trademarks, service marks, or other means of individualization, or individuals and legal entities, except for mentions of state authorities, other state bodies, local government bodies, municipal bodies, Sponsors, or socially oriented non-profit organizations (Parts 4 and 5 of Article 10 of the Law on Advertising). It follows from a literal interpretation of the law that if social advertising mentions information about a Sponsor and the services are rendered gratuitously, such advertising must still be recognized as social advertising and, therefore, be exempt from VAT.

Thus, correct tax calculation for sponsorship advertising requires a serious approach to drafting the relevant underlying documents, including the sponsorship aid agreement. Below, we examine the main characteristics of preparing such documents and provide several recommendations for mitigating key risks.

How to Properly Formalize Sponsorship Aid?

Essentially, sponsorship falls under the provisions of Chapter 39 of the Civil Code regarding the paid rendering of services.

To reduce the risk of reclassifying a sponsorship agreement and mitigate other risks, it is recommended to include the following in the sponsorship aid agreement:

• a condition on mentioning the organization as a Sponsor, and specifying the form of such mention (textual, logo, etc.);
• the purpose of the sponsorship contribution (precise identification of the event for which the sponsorship support is provided);
• the location of the advertising services (at conferences, presentations, webinars, etc.);
• the method of advertising distribution (e.g., through mass media, distribution of flyers, etc.);
• the term and dates of the advertising campaigns;
• the amount of sponsorship aid, the method of provision, and the procedure for its transfer;
• a condition on the procedure for exchanging documents to confirm operations with the sponsorship contribution and to confirm the rendering of advertising services (the procedure for invoicing, signing certificates of transfer and acceptance for the contribution and service results, set-off of reciprocal obligations, etc.);
• the liability of the advertising distributor (Sponsored Party) for compliance with advertising legislation;
• terms regarding the reciprocal performance of the agreement and its consideration;
• restrictions on the distribution of sponsorship advertising and other information, if such restrictions are legislatively established (e.g., for pharmaceutical companies), and other mandatory conditions for advertising distribution.

This article has reviewed the main legal aspects related to sponsorship and sponsorship advertising. It should be noted that despite available clarifications from authorities and judicial practice, an individual approach to legal analysis should be used for each sponsorship event and planned advertising campaign to assess legal risks.

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References

[1] Clause 21 of Information Letter of the Presidium of the Supreme Arbitration Court of the Russian Federation No. 37 dated December 25, 1998.

[2] Accounting for Internal and External Sources of Financing for the Activities of a Non-Profit Organization. Varpaeva I.A., Treushnikov R.V. // Accounting in Budgetary and Non-Profit Organizations. 2018. No. 19. P. 3.

[3] Legal Regulation of Advertising and Issues of Its Classification. Kirilin A.V., Sarnakov I.V. // Advertising and Law. 2014. No. 2. P. 55.

[4] Resolution of the Ninth Arbitration Appellate Court No. 09AP-50398/2019 dated February 4, 2020, in Case No. A40-75828/2019.

[5] Resolution of the Plenum of the Supreme Arbitration Court of the Russian Federation No. 58 dated October 8, 2012, On Certain Issues of the Practice of Application by Arbitration Courts of the Federal Law On Advertising.

[6] Article 1 of Federal Law No. 135-FZ dated August 11, 1995, On Charitable Activities and volunteering (Volunteering).

[7] Ruling of the Arbitration Court of the City of Saint Petersburg and the Leningrad Region dated August 7, 2020, in Case No. A56-63066/2019.

[8] Clause 21 of Information Letter of the Presidium of the Supreme Arbitration Court of the Russian Federation No. 37 dated December 25, 1998.

[9] Order of FAS Russia No. 821/23 dated November 14, 2023, On Approval of the Guidelines on Compliance with Mandatory Requirements "The Concept of Advertising".

[10] Letter of FAS Russia No. AK/1753/18 dated January 16, 2018, On Amendments to the Federal Law On Advertising.

[11] Order of FAS Russia No. 410/24 dated June 20, 2024, On Approval of Guidelines on Compliance with Mandatory Requirements in the Sphere of Advertising (together with the Guidelines on Compliance with Mandatory Requirements for Advertising of Specific Types of Goods (Advertising of Risk-Based Games, Betting), Guidelines on Compliance with Mandatory Requirements for Specific Methods of Advertising Distribution).

[12] Letter of the Federal Antimonopoly Service No. AK/13075 dated August 9, 2006.

[13] Decision of FAS Russia in Case No. RTs.08.10.12 dated June 3, 2010.

[14] Decision of FAS Russia dated May 26, 2015, in Case No. 3-24-47/00-08-14.

[15] Ruling of the Supreme Court of the Russian Federation No. 307-ES20-1922 dated March 23, 2020, in Case No. A56-119256/2018.

[16] Resolution of the Federal Arbitration Court of the Moscow District No. KG-A40/6309-05 dated July 22, 2005, and July 15, 2005.

[17] Resolution of the Federal Arbitration Court of the Moscow District No. KA-A40/1269-09 dated March 11, 2009.

[18] Recommendations on Compliance with Legislation on the Advertising of Non-Prescription Medicinal Products (prepared with the support of FAS Russia) dated November 7, 2018.

[19] Decision of FAS Russia dated April 27, 2021, in Case No. 08/05/24-38/2021.

[20] Letter of the Ministry of Finance of Russia No. 03-03-06/1/91717 dated December 17, 2018.

[21] Letter of the Ministry of Finance of Russia No. 03-03-06/4/5 dated January 17, 2013.

[22] Resolution of the Arbitration Court of the North Caucasus District No. F08-7174/2015 dated October 12, 2015, in Case No. A53-11626/2014.

[23] Letter of the Federal Tax Service of Russia No. MM-6-03/886@ dated October 19, 2005.

[24] Letter of the Ministry of Finance of Russia No. 03-07-11/39228 dated April 28, 2022.